In 2004, we introduced a new IT system to process debt collection cases. Unfortunately, this resulted in some data errors that caused us in some cases to collect debt that was time-barred (out of date) or to collect a larger amount than the customers owed us. The errors also mean that, for at large number of our debt collection customers, the registered outstanding debt is incorrect.

In May 2019, a comprehensive investigation was launched and the relevant authorities were notified. Since then, we have been working intensely to find a solution to the problems and compensate the affected customers for potential overcollection in relation to their overdue debt. Progress has been made on an ongoing basis, but at the same time, the scope and complexity of the case have increased. This means that the timeline for resolving the issues could extend beyond 2024, which is unsatisfactory for our customers and Danske Bank.

On the basis of extensive analyses, we have therefore worked to develop an accelerated solution that provides clarity for the vast majority of our debt collection customers. This means that a total of approximately 245,000 debt collection customers will be informed that their debt is set to zero and that their debt collection accounts will be closed. At the same time, we will compensate customers for any potential overcollection related to the additional issues on the basis of a statistical model.

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Between 2013 and 2019, it was the practice at Danske Bank to negotiate estate agent fees with all estate agents in Denmark except for the Danske Bank Group’s own estate agency chain home. Customers agreed to the fees in connection with the repayment of their debt.

Today, we have procedures that ensure that we treat all estate agents equally, including home.

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In connection with the analysis of the debt collection issue, we have found that we have wrongfully collected interest on reminder fees. The error arose in connection with an amendment of the Danish Interest Act (Renteloven) to which our systems were not adapted.

We are currently reviewing all reminder fees that we have charged in Denmark since 2005 – this concerns about 520,000 customers. We have identified a similar issue in Norway, where up to 184,000 customers may be affected.

The issues regarding the wrongful charging of interest on reminder fees also apply to Asset Finance Denmark (Nordania Leasing) and Asset Finance Norway.

Customers who have paid interest on reminder fees will of course be reimbursed and will receive compensation for the time that the money should have been at their disposal.

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While our customers have always seen the correct share price and received the correct amounts if they have traded shares, up to 27,000 personal and business customers across the Nordic countries and Luxembourg may have seen flawed estimates for profit and loss in Danske eBanking or Mobile Banking for example, due to shortcomings in an underlying IT system.

This concerns a limited number of shares that have been available on our trading platforms during the past 10 years.

Furthermore, around 60 Swedish customers have experienced wrong reporting of tax for a number of shares. We corrected our reporting to the Swedish Tax Agency and stopped displaying profit and loss figures for the potentially affected shares, until we had investigated them further.

In September 2021, a closing memo has been sent to the DFSA and we consider the case as closed.

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We have identified across the Nordic region, primarily in Denmark, that a number of investment agreements were registered incorrectly, resulting in discrepancies between the customers’ investment agreements and investment profiles. It affects around 600 customers and in some cases, the error dates back to 2007. It may have resulted in customers having achieved a lower or higher return than they would have achieved if the agreement had been registered correctly.

We are strengthening our controls and updating our processes for how investment agreements are registered to prevent similar errors from occurring again.

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Across our markets, some customers, primarily business customers, have not received the correct discounts on foreign exchange trades and foreign exchange in connection with international payments because the discounts were not registered correctly in our system in the period from 2009 to 2021.

We will reimburse the excess amount paid by the customers affected. We have tightened our procedures and have implemented an updated IT infrastructure to minimise the risk of similar errors in future.

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During the spring of 2020, we identified insufficiencies in internal processes supporting the tax services we offer customers with securities in their custody accounts. Consequently, we initiated a thorough review to uncover all potential issues.

Some of the issues may cause customer detriment because they may result in incorrect tax treatment of returns on securities or delays in services. Most of the customers affected are customers of Danske Bank in Denmark, the remainder being customers with Danske Bank in the other Nordic countries.

We are fully committed to solving the issues and ensuring that we provide our customers with correct tax treatment of their securities. In case an issue will result in a direct loss for the individual customer, we will of course compensate the customer.

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For less than 100 customers, the term of their loan have unfortunately become infinite, due to a lack of controls, which we failed to inform them about. In addition, we failed to follow up to ensure that customers had an appropriate repayment profile. The loan term had become infinite because payments did not cover interest accrued after interest rate increase in a period between 2007 and 2012.

Adjustments were made to ensure none of the affected loans have infinite terms and system changes are implemented, so that if the interest rate changes, we are able to prevent the loan term from extending beyond a certain limit.

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We have identified a number of business customers in Denmark who may have paid credit renewal fees which we did not have a basis for collecting. This was due to an issue in a system implemented in 2015, when we automated fee collection for business customers. We are examining a group of around 2,200 business customers who may be affected and began contacting them in January 2021. All affected customers will of course be compensated. We started paying compensation in April 2021.

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