Public consultation on Building a Capital Markets Union COM/2015/63 green paper

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1 Public consultation on Building a Capital Markets Union COM/2015/63 green paper Jelena Soskic European Policy Advisor phone: The Danish Chamber of Commerce welcomes the European Commission s green paper on Building a Capital Markets union. We believe that the Commission poses many relevant questions as to what will be needed in order to make capital flow more easily across member states to the benefit of European companies, growth and employment. The Danish Chamber of Commerce has focused its responses to 4 out of 32 questions that the Commission poses. We have answered to question 2, 5, 6 and 9. Response to question 2 in the CMU green paper The Danish Chamber of Commerce supports a European approach to harmonize and standardize SME data, at the same time we acknowledge quite a lot of challenges, which should be solved before it will be possible to develop a system that will work on a European level. One of the biggest challenges is the creditor s ability to verify the identification of a SME. The solution to this has already been explored on a global level and comes in a form of a Global Legal Entity Identifier (GLEI). Some EU countries are involved in this work and we believe that this could possibly work, as long as we are able to find the right balance between the need of information provided by SMEs and the level of administration they will have to cope with. Another crucial problem that stands in the way of SME credit information is the possibility of comparing data cross-border because of different credit cultures, market practices, definitions, and formats in which data is delivered on a national basis. We should therefore create a common EU language and definitions of what constitutes liable credit data for SMEs. We believe that digitalization has made it possible to collect huge amounts of data within a short time span, and will make it manageable to deliver and provide reliable data for all involved stakeholders (SMEs, credit data providers ect.) We believe that by implementing digital and technical solutions, we will be able to compare and better assess SME information from different countries, manage the costs involved, and increase efficiency in this respect. Along these lines, the Danish Chamber of Commerce believes that EU will need to develop a legal framework in order to regulate the collection, processing, and distribution of SME credit information. JSO Side 1/6 Dato:

2 We also encourage the Commission to find a model or solution to data ownership. Moreover, who will act as a credit rating service provider? Today central banks from nine European countries already operate credit registries and exchange credit information regularly on about SMEs each. Whether this will work on a European level will have to be explored As mentioned, to start with the Danish Chamber of Commerce finds it crucial that we ensure that SMEs will not be overburden by the level of data they will have to provide. We should make sure that they deliver the most crucial information in order to increase their possibilities of getting funding for their companies on a European capital market. Parallel to this we should continue our work to relieve European companies of unnecessary and burdensome administration. Response to question 5 in the CMU green paper In the years during and after the financial crisis in 2007, there has been a trend towards international standards for IPO prospectus because it has mainly been international banks, who have conducted IPO consortiums. The consequence of this is that companies that apply for admission to the stock exchange today face a far more extensive and detailed prospectus standard with a bigger risk section and more thorough disclaimers than before. This development has made the process towards an IPO excessively cumbersome, costly and less transparent for SMEs and has resulted in a drop in the number of listed SMEs in for example Denmark. The Danish Chamber of Commerce believes that there is a need for new and more flexible practices in using customized prospectus sizes and in ensuring more efficient approval procedures. We encourage new practices that will make it easier, cheaper and more transparent to prepare and get an approval from national FSAs. This is particularly relevant for smaller issuers, which typically are companies with a market capitalization below 270 million euros. We have found that it is possible to incorporate a practice where both the extent of the prospectus and the composition of the consortium reflects the size of the company. This will make the approval process run in a more efficient way, especially when it relates to SMEs. This is actually possible within the EU prospectus directive. At the same time, the Danish Chamber of Commerce would like to see far more smaller SMEs - meaning SMEs with a smaller annual turnover - on the stock market than we are seeing today. Currently the demand for the annual turnover of a SME, to be able to be listed on a stock exchange is very high, and excludes too many viable companies from entering funding through the stock exchange. We would like to lower the demand for a specific annual turnover in order to broaden the funding and growth possibilities of our European SMEs. Response to question 6 in the CMU green paper The Danish Chamber of Commerce has an ambiguous stand on SME securitization. The Danish experience with the securitization process has been of a mixed outcome since the Danish Parliament adopted a legislative package by the end of 2013, which gave banks the option of issuing Side 2/6

3 securitized corporate bonds for small and medium-sized enterprises. The aim was obviously to raise capital for the SME segment. However, the demand for the securitized corporate bonds was not as big as expected. We had hoped that especially the Danish Pension funds with an excess of liquidity would have been highly interested, but that has not been the case. So before taking any initiatives on a European level we would encourage a thoroughly examination of the kind of actors that are expected to be interested in investing in securitized bonds, and the potential demand. Another great concern of ours is that the securitized corporate bonds are often exposures of the least viable and profitable character. This obviously has great significance for the merit of the issued corporate bonds and thereby the demand for them. We believe that the securitization has a resemblance of subprime bonds that led to the financial crisis in the United States. The Danish Chamber of Commerce are well aware of the discussions regarding the proper and secure process of securitization on a European level. There have been several suggestions as to how this could be facilitated for SMEs, for example, the state could interfere by providing guaranties to some extent, or the banks could buy a minimum percentage of the issued securitized corporate bonds in order to confirm creditworthiness. However, none of these possible solutions has been tested in a Danish context. Lastly and most importantly, we are concerned about whether the necessary information about the companies in the securitized corporate bond series actually would or could be present, banks are likely to have sufficient information of companies to assess their creditworthiness, but banks can hardly be interested in revealing all the information they hold on companies. It would require a more neutral body to evaluate the creditworthiness of individual companies to be included in the securitization process. Response to question 9 in the CMU green paper The comments below are based on investments and execution of investments - in securities in the lower end of the market from 0,5 to 5 million euros. Contrary to the common belief amongst the general population, politicians and regulators there is nothing new to the concept of equity crowdfunding compared to traditional investment in and execution of securities. In the traditional system, a client would approach a broker dealer for advice and/or execution. Alternatively, a representative of the broker/dealer would approach a client with the aim of offering investment advice and undertake the subsequent transaction. A crowdfunding platform facilitates the contact between a company seeking funds and potential investors. The platform will provide the offer documents and the terms and will execute the transaction either on the platform or through an associated broker/dealer. The only difference between the traditional system and a crowdfunding platform is that the platform will not offer investment advice and the transaction is digital. It follows from this that MiFIDII in principle is perfectly suited to regulate equity crowdfunding. There are however a number of obstacles caused by different implementation of MiFIDII across the member states. Side 3/6

4 The Danish Chamber of Commerce believes that crowdfunding has the potential of becoming a key source of funding for entrepreneurs and SME s. We believe that we can only move too slowly in creating a European framework because member states have started to implement their own crowdfunding frameworks, which will contribute to fragmentation and impede cross border fundraising. Investor protection/investor categories The basis for investor protection is the investor category in this case the distinction between retail investors and professional (accredited) investors. To be an accredited investor in Denmark you will need to fulfil two out of the following three criteria: - the investor has made substantial transactions in the relevant area averaging 10 times per quarter in the last 4 quarters - the size of the investor s portfolio defined as cash and financial instruments exceeds EUR - the investor works or has worked in the financial sector for at least one year in a position requiring knowledge of the foreseen transactions or services If you do not fulfill the above, by definition you will be a retail investor. To become an accredited investor in UK you can self-certify and criteria s are significantly less restrictive compared to Denmark. It is evident that without a harmonized definition of investor categories it will be impossible to establish a common crowdfunding market. Retail investor limits unquoted papers/crowdfunding Crowdfunding platforms are subject to various limitations as to investment size. In Italy and in the recently proposed legislation in Spain and Germany there is an absolute cap on the annual amount a retail investor can place through a crowdfunding platform. In UK, the cap is a percentage of the investor s net wealth. In Denmark there is in principle no limit at all provided the platform be satisfied that the retail investor has sufficient skills and knowledge to enter the transaction/investment. It is evident that without a harmonized approach to investor limitations it will be impossible to establish a common crowdfunding market. Prospectus rules The prospectus rules as such do not represent a constraint it is the implementation and the exemptions in the individual member states that causes problems: In Denmark for example the threshold for a prospectus is 1 million euros in the UK it is euros. However, in the UK the potential investor can self-certify as accredited investor and thereby be included under one of the other exemptions. In Denmark strict criteria applies to accredited investors (see above) but since the threshold is 1 million euro s it is not really a constraint. Further, the Small Danish prospectus is quite simple and the Danish FCA has a 4-week approval process. Side 4/6

5 Platform regulation In principle, a MiFIDII compliant platform should be able to be pass ported throughout Europe in order to create cost and administrative efficiency also when undertaking crowdfunding. However, Europe s largest platforms being located in the UK are unable to passport into other EU countries as they operate under a local UK set of rules. We consider this as a mayor detriment to what we are trying to achieve with an internal market for capital and therefore encourage the Commission to make sure that all existing rules are implemented equally with the possibility of being pass ported as intended under MiFIDII. The platform s duties with respect to investor protection Another obstacle in relation to crowdfunding when it comes to MiFIDII is the requirements placed on the execution party (the platform if it is regulated otherwise an associated broker/dealer). In general, the platforms do not offer any investment advice at all and thereby the platform is not required to undertake the suitability assessment. However, the platform (or broker/dealer) is still required to assess the appropriateness of an investor s experience and expertise as well as the investors understanding of investment risk. In the UK, there is consensus between the FCA and the platforms as to how this should be done. However, it is evident that this is not the case across Europe, and we therefore need to harmonize in this area in order to be able to enhance cross border investments. Other considerations On another note, we also need to look at the barriers in the way of boosting retail investment. In Denmark for example the banks own the distribution channel and own/control the UCITS sector. In the UK, it is easier to boost retail investment partly due to the widespread role of the Independent Financial Advisors. Furthermore, we consider a reason for limited direct investment by retail investors is caused by of a lack of access to investment proposals. We believe that the web based crowdfunding platforms facilitate this access. Securitization is another important aspect in facilitating cross border fundraising and we believe it is necessary for other players to take part besides the banks. The AIFMD however has created an unnecessary cost and administration constraint for smaller funds creating a barrier of entry for new players. Alternative funds are beneficial from a portfolio point of view and thereby enhances investor protection. For crowdfunding, the small AIFMs are relevant. These however cannot be marketed to retail investors. Side 5/6

6 The Danish Chamber of Commerce believes that barriers to appropriately regulated crowdfunding across Europe can be removed by ensuring that financial regulations already in place are implemented similarly in order to create a level playing field for capital and investors in all countries. For example by making sure that platforms must meet MiFIDII requirements or have an execution party (broker/dealer) that meets such requirements. We believe that the appropriateness test implemented in the UK is a good best practice and could set the standard for the rest of Europe. As MiFIDII already is implemented, there are numerous resources for platforms that can enable swift implementation of national and cross border crowdfunding. We believe that a great deal of this can be done under existing legislation. And importantly: The regulators in each country as well as the financial sector is well acquainted with MiFIDII which again paves the way for swift implementation without the need for further training or staffing. Jelena Soskic European Policy advisor at the Danish Chamber of Commerce Side 6/6

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