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Minimum rules

for compliance tasks for Finance Denmark’s reference rates

A supplement to requirements stated in the Danish FSA’s regulation on reference rates.

Banks must ascertain that the following circumstances are continually assured:

  • that banks have drafted guidelines for setting and submitting individual reference rates;
  • that bank employees follow the set guidelines;
  • that the logbook is locked, archived and kept for a minimum of the current year and 5 years;
  • that employees, who fix quotas for reference rates, know that they may not allow themselves to be affected by others but that they must fix the rates based on their own evaluation on the basis of the banks guidelines. This includes that employees are informed that they must direct enquiries straight to the compliance function or another designated unit/person, if they experience that their impartiality in connection with the quoting system becomes compromised
  • ensure with ongoing spot checks that the contents and keeping of the logbook are satisfactory.

Particularly for CIBOR:

  • that there are limitations relating to the system, which ensure that the persons, who fix quotas for CIBOR do not have access to the bank’s or any group of companies’ exposure to the related products at an aggregate level;
  • the bank must ensure that an overall summary of the above circumstances takes place once a year.

The current rules do not consider where the tasks are to be attended to or carried out in the individual banks. It is, therefore, up to the individual bank to organise the work in the most appropriate manner.

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Finance Denmark is an business association for banks, mortgage institutions, asset management, securities trading and investment funds in Denmark. Our members are mortgage institutions, banks, savings banks, cooperative savings banks, Danish branches of foreign banks, asset managers, Danish securities dealers and investment funds. 

Read more about Finance Denmark and our work