Vi viser til Finansdepartementets brev av 4. mars 2015 vedrørende ovennevnte høring. Norges Bank har følgende synspunkter:

Norges Bank supports the Commission's initiative to create a more integrated capital market across European countries. However, it is worth noting that the potential for a large, single European capital market in line with, for example, the US market, might be limited by structural factors in European economies that is beyond the scope of this consultation. Examples of such factors could include considerations related to social security, pension saving regimes, demographic conditions, etc.

In line with the suggestions in the green paper, our view is that the main efforts must be directed towards increased transparency and standardization of the market, ref. the proposed new EU regulation to enhance transparency and data collection of securities financing transactions (SFT).

Concerning areas where the Commission has identified the need for progress, we specifically want to comment on the initiative to build sustainable securitization and support SMEs access to funding (Questions 1, 5 and 10).

A possible supplement to the proposal on building sustainable securitization for SMEs is to allow banks to issue bonds secured by SME loans. Such bonds, with a fixed maturity and a similar dual-recourse characteristic of covered bonds, might mitigate some of the shortfalls associated with off-balance sheet securitizations and could be attractive to a wide set of both institutional and other investors. Investors such as pension funds and life insurance companies would likely prefer such structures to ABS and securitized products. Creating a market for such bonds could be accomplished by supporting market-led initiatives and/or by ensuring that existing regulation does not create obstacles.

There are signs that regulation, technological changes and the shifting composition of market participants has reduced liquidity in some fixed income markets. Increasing concentration among asset managers and herding among retail investors could result in pro-cyclical behavior, and making markets increasingly susceptible to episodes in which liquidity suddenly vanishes and volatility spikes. More transparency and standardization would be helpful in this regard. Other measures to enhance market liquidity are discussed in the Spring 2015 Global Financial Stability Report from the IMF, including steps to address asset management funds' (including mutual funds) liquidity buffers, applying stricter stress testing, and establishing a minimum level for redemption fees. Both micro- and macro-prudential supervision of the asset management industry should be strengthened, and market safeguards like circuit breakers should periodically be reviewed to ensure they remain relevant. Lower market liquidity would reduce the benefits from more market based intermediation. Promoting liquid markets should be a key priority in building the capital market union (Questions 6 and 23).

Med hilsen

Ida Wolden Bache, Direktør

Sindre Weme, Direktør

Kopi: Finanstilsynet