FINANSTILSYNET. Danmarks Nationalbank To The Basel Committee on Banking Supervision Havnegade 5

Similar documents
On the Liquidity of Danish Mortgage Bonds

DANMARKS NATIONALBANK

DANMARKS NATIONALBANK

Financial Management at

DANMARKS NATIONALBANK

DANMARKS NATIONALBANK 6

DANMARKS NATIONALBANK

Danmarks Nationalbank. Danish Government Borrowing and Debt

DANMARKS NATIONALBANK 16

Activation of the countercyclical capital buffer

Danmarks Nationalbank. Stress Tests 2nd Half D A N M A R K S N A T I O N A L B A N K

Danmarks Nationalbank. Danish Government Borrowing and Debt

JYSKE REALKREDIT H1 REPORT Published 30 th of October 2018

ECBC Label Template for Danish Issuers 2014

DANMARKS NATIONALBANK

ECBC Label Template for Danish Issuers 2014

BOND TERMS BOND TERMS FOR KOMMUNEKREDIT 0.125% BULLET LOAN DUE Fixed rate non-callable bonds (hereafter the Bonds )

Interest Representative Registration ID number: Green Paper on Long-term Financing of the European Economy

FINAL TERMS FOR COVERED BONDS (SDO) issued by DLR KREDIT A/S. (hereafter DLR ) 1% Apr B 2020 IT2 (DKK)

Individual Solvency Need

Risk Report 2010Q4. Published 21 February 2011

Individual Solvency Need

To NASDAQ Copenhagen A/S Announcement no. 41/2017 The press. INTERIM FINANCIAL REPORT FIRST QUARTER OF 2017 BRFkredit

Danmarks Nationalbank. Danish Government Borrowing and Debt

econstor Make Your Publications Visible.

Risk Report 2010Q1. Published 12 May 2010

NASDAQ OMX Copenhagen A/S. 19 September 2011

Risk Report 2014Q1. Published 8 May 2014

Addendum no. 1, 2014, to Base Prospectus for covered bonds ( SDO ) issued by DLR Kredit A/S dated 27 May 2013

FINAL TERMS FOR COVERED BONDS (SDO) issued by DLR KREDIT A/S. (hereafter DLR ) 2% B 2050 IO (DKK)

FINAL TERMS FOR COVERED BONDS (SDO) issued by DLR KREDIT A/S. (hereafter DLR ) EURIBOR3 B 2028 (DKK)

Increase of the countercyclical capital buffer rate

FINAL TERMS. NORDEA BANK FINLAND PLC Issue of DKK 58,000,000 Range Accrual Notes Issued under the Euro 5,000,000,000 Medium Term Note Programme

FINAL TERMS FOR COVERED BONDS (SDO) issued by DLR KREDIT A/S. (hereafter DLR ) CIBOR6M B 2023 RF (DKK)

NASDAQ OMX Copenhagen A/S and the press 8 November 2012

Trade transparency and possible waivers and deferrals for non-equity instruments

DANMARKS NATIONALBANK 31

Jyske Bank Interim Financial Report First quarter of 2016

EBF Response to the EBA Consultations on currencies with constrained availability of Liquid Assets

In connection with the opening of new ISINs under Nykredit Realkredit A/S's Base Prospectus dated 13 May 2016, Nykredit issues new Final Bond Terms.

FINAL TERMS FOR COVERED BONDS (SDO) issued by DLR KREDIT A/S. (hereafter DLR ) 1% Jan B E IT (EUR)

FINAL TERMS FOR COVERED BONDS (SDO) issued by DLR KREDIT A/S. (hereafter DLR ) 2% Jan B 2019 (EUR)

FINAL TERMS FOR COVERED BONDS (SDO) issued by DLR KREDIT A/S. (hereafter DLR ) 2% Apr B 2019 (DKK)

Danish economic interest

FINAL TERMS FOR BONDS (Senor Secured Bonds) DKK2,000,000,000 FRN 2018/2021

Risk Report 2008Q4. Published 16 Marts 2009

FINAL TERMS FOR COVERED BONDS (SDO) issued by DLR KREDIT A/S. (hereafter DLR ) 2% B 2047 IO (DKK)

Price list for Admission to Trading and Issuance. Issuers of Bonds. May 2016

New EU-wide stress test: Large Danish banks withstand severe economic downturn

The risk of losses because the fair value of the Group s assets and liabilities varies with changes in market conditions.

In connection with the opening of new ISINs under Nykredit Realkredit A/S's Base Prospectus dated 13 May 2015, Nykredit issues new Final Bond Terms.

Abstract from the Nykredit publication: Danish Covered Bonds, April 2008 LEGAL FRAMEWORK

Non-Callable Loans for Cooperative Housing Societies

Statement by the management 16. Supplementary information 17. Realkredit Danmark First Nine Months /17

FINAL TERMS FIXED RATE NON-CALLABLE BULLET COVERED MORTGAGE BONDS ISSUED BY NORDEA KREDIT REALKREDITAKTIESELSKAB. CAPITAL CENTRE 2 ( Nordea Kredit )

Nordea Kredit Investor Presentation 2011 Q1. Published 18 May 2011

RESULTS Core income from business operations rose by a satisfactory 14% from DKK 2,485m in Q1-Q3/2009 to DKK 2,834m.

Liquidity Management in Connection with Settlement of Retail Payments

FINAL TERMS FOR BONDS (Senor Secured Bonds) DKK2,000,000,000 FRN 2016/2019

DANMARKS NATIONALBANK 12

New Final Bond Terms for Nykredit Realkredit A/S's Base Prospectus dated 15 May 2017

Consultation on Proposal for a regulation on European Crowdfunding Service Providers

DANMARKS NATIONALBANK 14

New Final Bond Terms for Nykredit Realkredit A/S's Base Prospectus dated 13 May 2015

Primary Dealer in Danish T-bills. Contract

Liquidity Coverage Ratio ( LCR ) For the quarter ended 31 Mar 2017

Final Terms Series 10G

FINAL TERMS VARIABLE RATE. MORTGAGE BONDS (Capital Centre 1) & COVERED MORTGAGE BONDS (Capital Centre 2) ISSUED BY

FINAL TERMS FOR COVERED BONDS (SDO) issued by DLR KREDIT A/S. (hereafter DLR ) CIBOR6M-20 B 2019 IO (DKK)

rate spread CIBOR6 + interest rate spread (non-callable)

Individual Solvency Need Nordea Bank Danmark Group 31 March 2012

Risk Report 2009Q3. Published 10 November 2009

Alm. Brand A/S SEB Nordic Seminar 2010

Danish FSA introduces the Supervisory Diamond for banks

DANMARKS NATIONALBANK 11

FINAL TERMS FIXED RATE CALLABLE COVERED MORTGAGE BONDS ISSUED BY NORDEA KREDIT REALKREDITAKTIESELSKAB. CAPITAL CENTRE 2 ( Nordea Kredit )

ICAAP Q Saxo Bank A/S Saxo Bank Group

FINAL TERMS FIXED RATE NON-CALLABLE. MORTGAGE BONDS (Capital Centre 1) & COVERED MORTGAGE BONDS (Capital Centre 2) ISSUED BY

DKK: Foreign ownership share of government bonds at post-crisis high

New Final Bond Terms for Nykredit Realkredit A/S's Base Prospectus dated 13 May 2015

Regulatory Practice Letter December 2013 RPL 13-20

DESCRIPTION OF FINANCIAL INSTRUMENTS AND ASSOCIATED RISKS

To Nasdaq Copenhagen A/S. 16 May Correction: New Final Bond Terms for Nykredit Realkredit A/S's Base Prospectus dated 13 May 2016

DANMARKS NATIONALBANK ASSESSMENT OF KRONOS

Interim Report Q Approved and published 27 April DLR Kredit A/S, Nyropsgade 21, 1780 København V, CVR NR.:

Jyske Bank in brief 3

FINAL TERMS FIXED RATE NON-CALLABLE. MORTGAGE BONDS (Capital Centre 1) & COVERED MORTGAGE BONDS (Capital Centre 2) ISSUED BY

Pillar 3 Disclosures. Liquidity Coverage Ratio ( LCR ) For the quarter ended 31 March 2016

FINAL TERMS VARIABLE RATE. MORTGAGE BONDS (Capital Centre 1) & COVERED MORTGAGE BONDS (Capital Centre 2) ISSUED BY

FINAL TERMS FIXED RATE NON-CALLABLE. MORTGAGE BONDS (Capital Centre 1) & COVERED MORTGAGE BONDS (Capital Centre 2) ISSUED BY

Housing finance in Norway

PRESS RELEASE. Securities issued by Hungarian residents and breakdown by holding sectors. April 2016

Portuguese Banking System: latest developments. 1 st quarter 2018

Individual Solvency Need

New Final Bond Terms for Nykredit Realkredit A/S's Base Prospectus dated 15 May 2018

What is going on in Basel?

Risk Report 2018Q1. Published 12 June 2018

> Realkreditobligationer (ROs) issued exclusively by mortgage banks. ROs are UCITS compliant (Article 52(4)).

Nordea Kredit, Investor Presentation, Q Published 28 November 2011

FIH Annual Rapport CVR-no

Transcription:

DANMARKS NATIONALBANK FINANSTILSYNET 23 august 2010 Sagsar 118061 Dokumentar : 1048869 Danmarks Nationalbank To The Basel Committee on Banking Supervision Havnegade 5 DK - 1093 København K Phone 33 63 63 63 Fax 33 63 71 03 Danmarks Nationalbank and Finanstilsynet strongly supports the aim of the sekr@nationalbanken.dk Basel Committee's capital and liquidity reform package. We are howevet www.nationalbanken.dk deeply concerned with the treatment of Danish covered bonds in the definition of liquid assets in the Liquidity Coverage Ratio. It is our assess- FINANSTILSYNET ment that the proposal of the 26th of July 2010 is more likely to increase the Arhusgade 110 risk of instability in the Danish financial system and thus run counter to the 2100 København Ø overall aim of the reform package. First, the proposal accords a much lower weight to covered bonds than gov- Tlf 33 55 82 82 Fax 33 55 82 00 CVR-nr 10 59 81 84 finanstilsynet@ftnet.dk ernment bonds in the Liquidity Coverage Ration (LCR) formula. We do not www.finanstilsynet.dk find that this is warranted by empirical evidence. In fact, the liquidity of Danish covered bonds has proven on par with that Danish Government SMONOMI-. ERHVERVSMINtSTERIET bonds in times of severe financial stress. Second, covered bonds are the predominant asset in the Danish financial market, and an important component of Danish financial institutions liquidity management. This is clearly illustrated by the shortfall in liquid assets for Danish banks under the proposal. This will be equivalent to approximately 8 1 per cent of the total outstanding amount of DKK denominated government bonds at end-2009. We, therefore, strongly suggest that a solution is found under which the liquidity of high quality covered bonds like Danish covered bonds is taken more appropriately into account. OG Please see the accompanying note for a more detailed explanation of our concerns and a possible solution. Yours sincere ils Bernstein Ulrik Nødgaard

23 august 2010 Sagsnr.: 118061 Dokumentnr.: 1048979 Danish covered bonds and the Liquidity Coverage Ratio (LCR) Covered bond liquidity is on par with that of Government bonds Danmarks Nationalbank is currently carrying out a study comparing the liquidity of the Danish government bond and covered bond markets before, during, and after the financial crisis based on a micro dataset. Due to the perspective of the study on liquidity risk management the study focuses on wholesale trades in the large bonds of the two markets. So far the empirical evidence does not support the idea that government bonds are more appropriate instrument in banks' liquidity pools than Danish covered bonds to the extent reflected in the revised LCR proposed on the 26th of July 2010. In fact, there was an increase in the number of trades, the median trade size as well as the turnover rate in the short end of the covered bond market during the crisis. Thus during the financial crisis long term covered bonds were just as liquid as long term government bonds, while short term covered bonds were actually more liquid than government bonds. Danmarks Nationalbank Havnegade 5 DK - 1093 København K Phone 33 63 63 63 Fax 33 63 71 03 sekr@nationalbanken.dk www.nationalbanken.dk FINANSTILSYNET Århusgade 110 2100 København Ø Tlf 33 55 82 82 Fax 33 55 82 00 CVR-nr 10 59 81 84 finanstilsynet@ftnet.dk www.finanstilsynet.dk ØKONOMI- OG ERHVERVSMINISTERIET This can be documented by looking at an often used measure of illiquidity, namely the percentage price change divided by trade size 1. Based on this measure a tendency can be seen that before the crisis government bonds were slightly more liquid than covered bonds, cf. chart 1 and 2, and this normal relationship has be re-established. Furthermore the short term covered bond market has been as liquid as the long term government bond market. 1 Amihud, Y. (2002). Illiquidity and Stock Returns: Cross-Section and Time-Series Effects. Journal of Financial Markets 5(1), 31-56.

2 MONTLY MEDIAN OF PERCENTAGE PRICE CHANGE DIVIDED BY TRADE SIZE Chart 1 0.00045 0.0004 0.00035 0.0003 0.00025 0.0002 0.00015 0.0001 0.00005 0 Jan-2005 Apr-2005 Jul-2005 Oct-2005 Jan-2006 Apr-2006 Jul-2006 Oct-2006 Jan-2007 Apr-2007 Jul-2007 Oct-2007 Jan-2008 Apr-2008 Jul-2008 Oct-2008 Jan-2009 Apr-2009 Jul-2009 Oct-2009 Jan-2010 Apr-2010 Long term covered bonds Long term government bonds Note: Source: Long term covered bonds are defined as long term callable mortgage-bonds. Long term government bonds are defined as government bonds with time to maturity of more than five years. Danish Financial Supervisory Authority, Nasdaq OMS and own calculations. The illiquidity measure for both the long term government and covered bond market increased significantly during the crisis. However, the level of the illiquidity measure was almost the same for the two markets during the peak of the crisis. This does not take into account the temporary measures undertaken during the financial crisis to support the Danish pension sector. In the short end of the markets the illiquidity measure was higher for government than covered bonds during several months of the crisis. Part of this result can be explained by the fact that the short term government bonds, being defined as bonds with time to maturity of less than five years, generally have a longer time to maturity than the short term covered bonds. However, the very short end of the government bond market would by no means be sufficient to cover the banks need for liquid assets under the Basel proposal. Actually, the Basel proposal would induce the banks to hold long term government bonds as liquidity, cf. the calculations below based on the Quantitative Impact Study (QIS).

3 MONTLY MEDIAN OF PERCENTAGE PRICE CHANGE DIVIDED BY TRADE SIZE Chart 2 0.00045 0.0004 0.00035 0.0003 0.00025 0.0002 0.00015 0.0001 0.00005 0 Jan-2005 Apr-2005 Jul-2005 Oct-2005 Jan-2006 Apr-2006 Jul-2006 Oct-2006 Jan-2007 Apr-2007 Jul-2007 Oct-2007 Jan-2008 Apr-2008 Jul-2008 Oct-2008 Jan-2009 Apr-2009 Jul-2009 Oct-2009 Jan-2010 Apr-2010 Short term covered bonds Short term government bonds Note: Short term covered bonds are defined as fixed-rate bullet mortgage bonds. Short term government bonds are defined as Source: government bonds with time to maturity of less than five years. Danish Financial Supervisory Authority, Nasdaq OMS and own calculations. The high liquidity of Danish covered bonds during the crisis can in large part be attributed to the history and institutional setup of Danish covered bonds. In Denmark there is a very long history for issuing covered bonds under a strict legislative framework. Danish covered bonds are, on top of the general characteristics of covered bonds, issued under a very strict "balance principle" that strongly limits the issuers' ability to assume any risks other than credit risk. In practice the vast majority of loans financed by covered bonds have loan terms including interest rate and method of prepayment which are set with direct reference to the terms of the covered bonds issued to fund the loan. As the bonds are exchange-listed the system is highly transparent. The close link between loans and bonds makes it possible for the borrowers to repay their loans by buying the underlying bonds. Thus the covered bonds cannot trade with a very large discount compared to the credit quality of the cover assets without attracting buy-side interest from the borrowers. The strict balance principle also strongly limits the mortgage banks ability to assume any other risks than credit risk. The credit risk is contained by a number of measures. Besides the maximum loan-to-value ratio of 80 pct. at all times of the loan, mortgages have a strong legal position in Denmark. The mortgage banks possess a senior claim on the proceeds from a property sale in the event of a borrowers default. The Danish foreclosure processes are fast at relatively low cost and strategic default by borrowers is eliminated by borrowers personal liability in the Danish legislation. The high quality of the Danish covered bond system has also been demonstrated by the fact that the system has worked well in providing a stable source of credit to households and firms during the financial crisis. In fact increased lending funded by covered bonds has offset a fall in lending by

4 the rest of the banking system. Its significance can also be illustrated by the fact that the market value of all covered bonds is more than EUR 300 billion. This is equivalent to 1.4 times Denmark's GDP and 7.6 times as large as the Danish government debt. Covered bonds are central to Danish banks liquidity management The results of the Quantitative Impact Study (QIS) underline the importance of the covered bond market to the Danish financial sector. Table 1 shows weighted average estimates of the Liquidity Coverage Ratio for the Danish institutions taking part in the QIS. LCR ESTIMATES FOR DANISH QIS BANKS (WEIGHTED AVERAGE) Table 1 Limit on Level 2 assets Baseline scenario of December 2009 proposal Broad buffer scenario of December 2009 proposal Scenario of GHoS press release of 26 July 0 per cent 34 per cent 40 per cent 56 per cent 59 per cent 50 per cent 68 per cent 71 per cent 100 per cent 81 per cent 89 per cent Note: Calculations under the GHoS scenario are made under simplifying assumptions given the level of detail in the original QIS While the GHoS scenario stipulates a limit on level 2 assets in the portfolio of liquid assets at 40 pct., calculations have also been made based on alternative limits but using the same stress scenario. Own issued covered bonds currently held in the portfolio of liquid assets are excluded from the calculation Under the baseline scenario of the Basel December 2009 proposal the Danish banks obtain a weighted average Liquidity Coverage Ratio (LCR) of 34 per cent. Allowing covered bonds to be included in the portfolio of liquid assets significantly improves the LCR, up to a level of 89 per cent given full inclusion. The substantial impact on the LCR is due to the relatively small government debt market in Denmark and a large and well developed covered bond market. Covered bonds are the predominant asset in the Danish financial market, and an important component of Danish financial institutions liquidity management. In 2009 one third of the Danish mortgage bonds were held by monetary financial institutions. Under the July 26th scenario of the Group of Governors and Heads of Supervision (GHoS) the total shortfall in liquid assets is EUR 28 billion for the Danish banks taking part in the QIS. This is equivalent to 49 per cent of the total outstanding amount of DKK denominated government bonds excluding holdings in government funds at end-2009, c.f. table 2.

5 NOMINAL AMOUNT OF DKK GOVERNMENT BONDS AND DKK COVERED BONDS IN CIRCULATION AT END 2009, DISTRIBUTED BY REMAINING TIME TO MATURITY Table 2 Billion EUR time to maturity <= 5 years 5 years < time to maturity <= 10 years Time to maturity > 10 years Total Outstanding amount of DKK government bonds 29,9 22,9 15,2 67,9 - Amount held by government funds 7,2 1,9 1,3 10,4 - Amount held by Danish monetary financial institutions 3,1 4,2 0 7,3 Remaining amount of DKK government bonds in free circulation 19,6 16,7 13,8 50,2 Outstanding amount of DKK covered bonds 197,9 29,8 135,2 362,9 Source: Danmarks Nationalbank Extrapolating the shortfall figure to the entire Danish banking sector on the basis of total assets, and subtracting any current holdings of Danish government bonds by Danish monetary financial institutions, the shortfall is equivalent to 81 per cent of Danish government bonds in circulation. Requiring Danish financial institutions to hold such a very large proportion of the government bonds in circulation in a liquidity buffer would in itself negatively impact the liquidity of these bonds. Finally, as evident from table 2, a large proportion of Danish government bonds outstanding are very long-term bonds, not well suited as liquidity risk management instruments. In contrast, a large amount of short term covered bonds exist. Conclusion In conclusion, Danish covered bonds have proven to be very liquid even during times of stress and are subject to a very strict legal structure. Hence, there is no evidence to support the treatment of Danish covered bonds vis-avis government bonds in the current proposal. In addition, the large and important Danish covered bond market in combination with a significant shortfall of government bonds under the current proposal may create severe tensions in the Danish financial system. We therefore strongly suggest that a solution is found under which the liquidity of high quality covered bonds like Danish covered bonds is taken more appropriately into account. High quality covered bonds should be included in the definition of "level 1" liquid assets. If not, the cap on high quality covered bonds should be lifted considerably. Given the insufficient availability of currently defined "level 1" assets in Denmark, a solution must be found so that Danish high quality covered bonds can be included as liquid assets in the LCR of Danish banks to a higher extent than the current proposal allows.