National Bank of Denmark governor Lars Rohde expressed concern that Danish mortgage banks will not be covered by bail-in tools, in a speech on October 1.

Mortgage banks are covered by Europe's bank recovery and resolution directive, but the minimum requirement for own funds and eligible liabilities, a standard requiring banks to hold sufficient loss-absorbing capital, does not apply to them. Instead they maintain an additional "debt buffer" of 2% of their lending.

This means bail-in "is not an