| Country Manuals Private Banking – We would like to inform you that BRP has updated its COUNTRY MANUAL PRIVATE BANKING for the following jurisdiction: DENMARK OUT OF BANK’S COUNTRY OF ESTABLISHMENT (Def, RS, BT & RT) Regulatory Template Material changes The Manual has been reviewed to take account of an evolving interpretation of the applicable legal and regulatory framework. Following consultation with our local lawyers, the update reflects a slightly less strict interpretation of the permissibility of banking or investment activities undertaken on Danish territory in response to a prospect’s or client’s request (reverse solicitation). In case of genuine reverse solicitation (i.e. provided no previous marketing has occurred in violation of Danish cross-border rules), the foreign bank may respond to a prospect’s or client’s request during occasional on-site meetings. However, due to the strict territorial approach taken by Danish financial supervisory authorities to onsite activities, a cautious approach is still recommended and the foreign bank should avoid a frequent or intense presence on Danish territory. Without prejudice to the foregoing, we can otherwise confirm that there have not been any relevant regulatory changes in Denmark since the last update. Implications for business relations with third parties There have been no substantial changes to the answers when a foreign bank co-operates with third parties. Non-material changes Certain comments have been slightly reworded (without introducing material changes) to reflect the new format of the document. Regulatory Summary The document has been reformatted onto the latest template. Behaviour Template The answers in the BT have been aligned to those contained in the RT. BT Short Comparison BRP has created a comparison document allowing users to quickly identify the modifications made compared to the previous version of the PB Manual (BT Short Comparison). The BT Short Comparison can be found on BRP’s platform (mybrponline) in the Search tab by entering in the Document Field “CM PB BT SHORT COMP” and “DENMARK” in the Target Country Field. The BT Short Comparison should be read as follows: The first column contains a short description of the activity in question. The second column contains the answers of the previous version of the Country Manual (online until the day of the alert). The third column contains the new answers of the most recent version of the Country Manual. Only the modified answers are displayed (in color). If the answers in the new version are unchanged compared to the previous version, they are shaded in grey. Best regards, |
