On May 31, the Ministry of Finance published the draft bill "DNB Mortgage Market Reporting Act. This bill aims to create a legal authority for DNB for data-driven supervision. We indicated in our June 28 response that we are not convinced that introducing this reporting requirement is necessary.
While we understand DNB's need for information from financial institutions for its financial stability mission or for statistical purposes, we believe the bill is unnecessary to achieve this goal.
Necessity and proportionality
We question the justification for the necessity of the proposed reporting obligation on mortgage data to DNB. There is insufficient justification for this reporting obligation, especially since DNB already has statutory query authority. We also feel that the examination of whether the reporting obligation is proportionate is insufficiently substantiated. In order to make the impact of the draft bill proportionate and reduce the burden on the industry, we suggest that the Ministry of Finance consider avoiding double reporting.
Privacy and industry impact
The proposed reporting obligation inevitably leads to additional ICT costs and system adjustments at financial companies. Precisely because the reporting obligation involves consumer data that must be separated from privacy-sensitive data. This requires system adjustments and additional investments. We are also concerned about whether privacy is always guaranteed.
Goldplating
The bill is a form of "goldplating" that is undesirable. It is important that financial firms established in the Netherlands should not be put at a disadvantage relative to their competitors abroad as a result of this bill. If data-driven supervision is to be introduced, it should be done at the European level and not at the national level.
