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Finanssiala ry - Finance Finland

FA - FFI

Finance Finland represents banks, insurers, and other financial services companies operating in Finland.

Lobbying Activity

Meeting with Paulina Dejmek Hack (Cabinet of Commissioner Jessika Roswall) and Finance Norway and

15 Jan 2026 · The link between insurance and the environment portfolio, resilience, simplification, the Single Market

Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union) and

14 Jan 2026 · Exchange of views on insurance related aspects of the pension package/SIU

Finance Finland Urges Lighter Reporting Burden in Taxonomy Review

5 Dec 2025
Topic — The initiative reviews environmental delegated acts to update and simplify technical screening criteria.
Message — FFI demands that reporting requirements for the financial sector do not create an unjustly heavier burden. Indicators like the Green Asset Ratio should only cover companies obliged to report under the CSRD. They advocate for removing minimum safeguards and DNSH assessments for households to reduce complexity.123
Why — This would reduce administrative complexity and prevent stagnation in the development of sustainable products.4
Impact — Environmental transparency declines if manufacturing technologies bypass mandatory third-party verification for life-cycle greenhouse emissions.5
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Meeting with Stéphanie Yon-Courtin (Member of the European Parliament, Rapporteur)

13 Oct 2025 · Retail Investment Strategy

Meeting with Kira Marie Peter-Hansen (Member of the European Parliament)

8 Oct 2025 · Meeting with Finance Finland

Meeting with Elsi Katainen (Member of the European Parliament)

7 Oct 2025 · Current issues in the finance sector

Meeting with Aura Salla (Member of the European Parliament)

7 Oct 2025 · Online fraud and banking scams, which also relate to the upcoming ProtectEU strategy and its Action Plan on Online Fraud, the role of artificial intelligence in the financial sector and on regulatory issues related to it

Meeting with Eero Heinäluoma (Member of the European Parliament)

7 Oct 2025 · Finanssialan ajankohtaiset asiat

Meeting with Tomas Tobé (Member of the European Parliament) and Finance Denmark and

24 Sept 2025 · Finance Policy

Meeting with Katri Kulmuni (Member of the European Parliament) and Finance Denmark and

24 Sept 2025 · Nordic Finance evening -vastaanotto

Meeting with Sebastian Tynkkynen (Member of the European Parliament)

24 Sept 2025 · Nordic Finance Evening

Meeting with Antti Timonen (Cabinet of Executive Vice-President Henna Virkkunen), Marlene Rosemarie Madsen (Cabinet of Executive Vice-President Henna Virkkunen) and

24 Sept 2025 · Exchange about important digital policy priorities with representatives of Nordic Financial Associations

Meeting with Sirpa Pietikäinen (Member of the European Parliament) and Insurance Europe

19 Sept 2025 · EU’s Sustainable Finance Framework, the Savings and Investments Union

Finance Finland backs flexible EU investment account blueprint

8 Jul 2025
Topic — The Commission is creating a blueprint for savings and investment accounts for retail investors.
Message — Finance Finland requests a simple framework for diverse assets like shares and insurance products. They advocate for removing geographical restrictions and mandatory minimum holding periods.123
Why — Wider tax incentives would increase investment levels and reduce costs through higher competition.4
Impact — Providers of long-term products lose market dominance as broader incentives increase competition.5
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Meeting with Sebastian Tynkkynen (Member of the European Parliament) and Helsinki EU Office

2 Jul 2025 · Iltavastaanotto

Response to Digital services for simplifying business operations and reducing administrative costs – the business wallet

12 Jun 2025

Finance Finland is the common voice of the Finnish financial sector and represents the interests of its members. We represent banks, life and non-life insurers, employee pension companies, finance houses, fund management companies and securities dealers operating in Finland. The EU Business Wallet initiative has the potential to reduce administrative burden and improve regulatory compliance by fostering the use of digital credentials. By focusing on credentials, enabling public sector participation, and supporting a flexible trust framework, the initiative can unlock new opportunities for businesses to thrive in the digital economy. Put the focus on the Digital Credentials: The core value of digital credentials lies in their ability to facilitate automated processing and verification. When credentials are structured and machine-readable, they can be processed automatically. When digitally signed, their authenticity and integrity can be verified without manual intervention. Digital Wallets: These serve as tools for acquiring, managing, and sharing credentials. The specific form of the wallet is less important than the ability to participate in trusted digital interactions. Flexibility and Innovation: The legislation should prioritize flexibility in implementation, allowing room for innovation to enable market dynamics to shape the most effective solutions. The prospect of new revenue streams or cost reductions are usually enough of an incentive for the private sector. Public Sector Participation: Regulatory focus should be on empowering public sector organizations to issue and accept digital credentials. This will accelerate adoption and interoperability across industries. The upcoming regulation should mainly focus on the public sector. Trust Framework: A robust trust framework is essential for the reliability of digital credentials. Competent authorities should attest to the legitimacy of issuers, ensuring real, verifiable trust. Legal Framework: The regulation should define the legal environment for trusted digital interactions, not prescribe technical implementations. Interoperability is crucial, and additional technical mandates could stifle innovation.
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Meeting with Jussi Saramo (Member of the European Parliament)

10 Jun 2025 · Banking regulation and macro stability

Finance Finland urges simpler sustainable finance rules and labeling

30 May 2025
Topic — This consultation evaluates EU rules for financial sector sustainability disclosures to prevent greenwashing.
Message — The organization proposes a product grouping system based on measurable data rather than subjective terms. They recommend shortening reporting forms and removing mandatory disclosures for products that do not claim sustainability goals.123
Why — Simplified reporting and fewer data requirements would significantly lower compliance and implementation costs.4
Impact — Retail investors would lose access to standardised sustainability information for products categorized as unclassified.5
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Meeting with Arba Kokalari (Member of the European Parliament, Rapporteur) and Deutsche Bank AG and

30 Apr 2025 · AI in Financial Services

Meeting with Marlene Rosemarie Madsen (Cabinet of Executive Vice-President Henna Virkkunen)

24 Apr 2025 · Exchange of views on online fraud and online financial scams

Finance Finland urges logical reforms to EU Taxonomy reporting

26 Mar 2025
Topic — The Commission proposes amending Taxonomy Delegated Acts to simplify sustainability reporting for businesses.
Message — Finance Finland supports a 10% materiality threshold but requests clearer calculation instructions. They advocate for symmetrical accounting in financial indicators and simpler environmental criteria.1234
Why — Companies would lower compliance costs and redirect resources to other sustainability work.5
Impact — Investors face less comparable data and increased risks of unintended greenwashing.6
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Meeting with Sebastian Tynkkynen (Member of the European Parliament)

26 Mar 2025 · Pohjoismaiden finanssialojen asiat

Meeting with Eero Heinäluoma (Member of the European Parliament)

21 Mar 2025 · Pääomamarkkina-, Säästö- ja sijoitusasiat

Response to Savings and Investments Union

7 Mar 2025

Please find attached Finance Finland's feedback to this consultation.
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Meeting with Anna-Maja Henriksson (Member of the European Parliament)

7 Mar 2025 · Banking

Meeting with Sebastian Tynkkynen (Member of the European Parliament)

6 Mar 2025 · Finanssialan ajankohtaiset sääntelyhankkeet

Meeting with Sirpa Pietikäinen (Member of the European Parliament)

18 Feb 2025 · EU finance regulation

Meeting with Jussi Saramo (Member of the European Parliament)

7 Feb 2025 · Banking regulation and retail investment services

Meeting with Sirpa Pietikäinen (Member of the European Parliament)

7 Feb 2025 · Finance Finland seminar for Finnish MEP Assistants

Meeting with Sebastian Tynkkynen (Member of the European Parliament)

7 Feb 2025 · Ajankohtaiset asiat

Meeting with Merja Kyllönen (Member of the European Parliament)

7 Feb 2025 · Tilaisuus EU-parlamentin avustajille

Meeting with Katri Kulmuni (Member of the European Parliament)

6 Feb 2025 · Ajankohtaiset EU-asiat

Meeting with Tilman Lueder (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

4 Feb 2025 · Finnish financial industry, including life and non-life insurance companies and statutory pension insurance undertakings providing services in Finland.

Meeting with Aura Salla (Member of the European Parliament)

12 Dec 2024 · PSD3, RIS, CMU, Securitisation

Meeting with Sebastian Tynkkynen (Member of the European Parliament) and Confederation of Finnish Industries EK and

3 Dec 2024 · Ajankohtaiset aiheet

Meeting with Katri Kulmuni (Member of the European Parliament)

29 Oct 2024 · Paneelikeskustelu

Meeting with Markus Ferber (Member of the European Parliament)

9 Oct 2024 · Future developments in the EU financial sector

Meeting with Stine Bosse (Member of the European Parliament)

8 Oct 2024 · European financial policy

Meeting with Elsi Katainen (Member of the European Parliament)

8 Oct 2024 · Tuleva kausi

Meeting with Mika Aaltola (Member of the European Parliament)

8 Oct 2024 · Financial Policy

Meeting with Kira Marie Peter-Hansen (Member of the European Parliament)

8 Oct 2024 · Future developments in EU financial sector

Meeting with Pekka Toveri (Member of the European Parliament)

8 Oct 2024 · Current Topics in EU politics

Meeting with Katri Kulmuni (Member of the European Parliament)

8 Oct 2024 · Finanssialan ajankohtaiset sääntelyhankkeet

Meeting with Adnan Dibrani (Member of the European Parliament)

8 Oct 2024 · Finansiella frågor i Norden

Meeting with Eero Heinäluoma (Member of the European Parliament) and Musiikkituottajat - IFPI Finland ry

8 Oct 2024 · Ajankohtaisaiheet

Meeting with Maria Guzenina (Member of the European Parliament)

8 Oct 2024 · Current affairs

Meeting with Maria Ohisalo (Member of the European Parliament)

8 Oct 2024 · Exchange of views on the ongoing legislature

Meeting with Eero Heinäluoma (Member of the European Parliament) and Finnish Energy - Energiateollisuus ry and

1 Oct 2024 · Ajankohtaisaiheet

Meeting with Anna-Maja Henriksson (Member of the European Parliament)

1 Oct 2024 · Financial sector and regolatory projects

Meeting with Sebastian Tynkkynen (Member of the European Parliament) and Finance Denmark and Finance Norway

25 Sept 2024 · Pohjoismaisten finanssialajärjestöjen tilaisuus

Finance Finland calls for ATAD reform following GloBE introduction

11 Sept 2024
Topic — This consultation evaluates EU rules addressing aggressive tax planning and tax avoidance practices.
Message — Finance Finland warns that overlapping tax rules create a risk of double regulation. They suggest ATAD's provisions may become redundant because global rules address similar objectives. The group recommends harmonizing rules into a single framework to facilitate compliance.123
Why — Consolidating these rules would reduce administrative burdens and complexities for multinational enterprises.4
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Meeting with Nils Torvalds (Member of the European Parliament)

27 Jun 2024 · The upcoming term in the European Parliament

Meeting with Alviina Alametsä (Member of the European Parliament)

26 Jun 2024 · EU elections´ results

Meeting with Sirpa Pietikäinen (Member of the European Parliament)

8 Mar 2024 · European deposit insurance scheme

Meeting with Sirpa Pietikäinen (Member of the European Parliament)

14 Feb 2024 · Retail investor strategy

Meeting with Sirpa Pietikäinen (Member of the European Parliament)

22 Jan 2024 · Fida and payment services

Response to Drinking water - conformity assessment procedure

9 Nov 2023

Finance Finland (FFI) represents the Finnish banking and insurance sectors. Our members include nearly all banks, life and non-life insurers, employee pension companies, finance houses, fund management companies and securities dealers operating in Finland. FFI objects to the exclusion of dezincification resistant brass alloys from the positive lists regarding materials that come into contact with drinking water. In practice, this pertains to the various components used in water supply systems. The brass alloys have type approval in Finland and have been appropriately notified to ECHA, and FFI demands that they are included in the European positive lists. The quality of drinking water varies between member states, making it necessary to set different national requirements for the materials used in water supply systems. In Finland, for example, it is necessary to use dezincification resistant brass alloys. The dezincification resistance is achieved by adding small amounts of lead in the alloy. Fitting water supply systems with brass parts that are not resistant to dezincification would lead to their premature failure and leaks and thus contribute to a significant increase in the number of moisture and mould damages. Over the last decade, Finnish insurance companies annually paid out EUR 145188 million in compensations for leak damages. The number of claims ranged between 28,000 and 42,000 per year. In 2022, for example, the number of claims was 28,000 for a total of EUR 157 million. It should be noted that the figures only include losses that were covered by insurance. Insurance does not, for example, cover damages from slowly developing dampness or mould, which are immensely common. Only sudden and unforeseen water leak damages are compensated. Nevertheless, the number of claims incurred from water damages is much higher than from fire damages in both home insurance and real estate insurance. Excluding the dezincification resistant materials from the positive list would cause significant economic and technical problems, especially considering how short the transition period proposed by the Commission is. If the Commission nevertheless wants to prohibit the use of the brass alloys type-approved in Finland, it must provide a sufficient transition period to enable real opportunities to develop durable, sustainable and otherwise suitable materials to replace the existing ones. The transition period must be at least ten years, and the national type approvals must remain valid for the entire transition period. Finding workable solutions is further complicated by the European Commissions circular economy action plan, which includes legal requirements for example concerning the sustainability and recyclability of construction products throughout their entire lifecycle from design to demolition. The Finnish brass industry is almost fully circular, based on 90% recycled materials. Manufacturing scrap and used brass products are turned into high-quality secondary raw materials. The industry currently operates perfectly in line with the aims of the EU circular economy action plan and stands as an example of how sustainable product design can minimise the environmental and climate impact of a products lifecycle. The modern Finnish practices reduce waste and emissions by generating secondary raw materials from resources that were formerly classified as waste. The Commissions proposal undermines its very own aims for a circular economy if it prohibits the use of a durable solution and prevents the use of recycled materials in its potential substitutes by requiring the use of primary metals in production.
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Response to Drinking water - establishing the European Positive Lists of starting substances

9 Nov 2023

Finance Finland (FFI) represents the Finnish banking and insurance sectors. Our members include nearly all banks, life and non-life insurers, employee pension companies, finance houses, fund management companies and securities dealers operating in Finland. FFI objects to the exclusion of dezincification resistant brass alloys from the positive lists regarding materials that come into contact with drinking water. In practice, this pertains to the various components used in water supply systems. The brass alloys have type approval in Finland and have been appropriately notified to ECHA, and FFI demands that they are included in the European positive lists. The quality of drinking water varies between member states, making it necessary to set different national requirements for the materials used in water supply systems. In Finland, for example, it is necessary to use dezincification resistant brass alloys. The dezincification resistance is achieved by adding small amounts of lead in the alloy. Fitting water supply systems with brass parts that are not resistant to dezincification would lead to their premature failure and leaks and thus contribute to a significant increase in the number of moisture and mould damages. Over the last decade, Finnish insurance companies annually paid out EUR 145188 million in compensations for leak damages. The number of claims ranged between 28,000 and 42,000 per year. In 2022, for example, the number of claims was 28,000 for a total of EUR 157 million. It should be noted that the figures only include losses that were covered by insurance. Insurance does not, for example, cover damages from slowly developing dampness or mould, which are immensely common. Only sudden and unforeseen water leak damages are compensated. Nevertheless, the number of claims incurred from water damages is much higher than from fire damages in both home insurance and real estate insurance. Excluding the dezincification resistant materials from the positive list would cause significant economic and technical problems, especially considering how short the transition period proposed by the Commission is. If the Commission nevertheless wants to prohibit the use of the brass alloys type-approved in Finland, it must provide a sufficient transition period to enable real opportunities to develop durable, sustainable and otherwise suitable materials to replace the existing ones. The transition period must be at least ten years, and the national type approvals must remain valid for the entire transition period. Finding workable solutions is further complicated by the European Commissions circular economy action plan, which includes legal requirements for example concerning the sustainability and recyclability of construction products throughout their entire lifecycle from design to demolition. The Finnish brass industry is almost fully circular, based on 90% recycled materials. Manufacturing scrap and used brass products are turned into high-quality secondary raw materials. The industry currently operates perfectly in line with the aims of the EU circular economy action plan and stands as an example of how sustainable product design can minimise the environmental and climate impact of a products lifecycle. The modern Finnish practices reduce waste and emissions by generating secondary raw materials from resources that were formerly classified as waste. The Commissions proposal undermines its very own aims for a circular economy if it prohibits the use of a durable solution and prevents the use of recycled materials in its potential substitutes by requiring the use of primary metals in production.
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Meeting with Eero Heinäluoma (Member of the European Parliament)

26 Oct 2023 · Topical Issues

Meeting with Eero Heinäluoma (Member of the European Parliament, Shadow rapporteur)

9 Oct 2023 · Retail investment strategy

Meeting with Eero Heinäluoma (Member of the European Parliament)

12 Sept 2023 · Topical issues

Meeting with Ondřej Kovařík (Member of the European Parliament, Rapporteur)

12 Sept 2023 · PSD III

Meeting with Nils Torvalds (Member of the European Parliament)

12 Sept 2023 · Actual EU-policy matters

Meeting with Sirpa Pietikäinen (Member of the European Parliament)

12 Sept 2023 · Relevant ECON files

Meeting with Henna Virkkunen (Member of the European Parliament)

12 Sept 2023 · Perspectives from the Finance Industry

Meeting with Alviina Alametsä (Member of the European Parliament)

11 Sept 2023 · Exchange of views

Meeting with Eero Heinäluoma (Member of the European Parliament)

11 Sept 2023 · Topical Issues

Response to Banking Union: Review of the bank crisis management and deposit insurance framework (DGSD review)

30 Aug 2023

Finance Finland (FFI) welcomes the efforts to improve the Banking Unions crisis management tools. The Commissions proposal has many good suggestions which help improve crisis resolution, such as increasing information exchange between supervisory and resolution authorities. Timely intervention by the authorities is of essence to avoid the depletion of capital buffers in banks that are failing or likely to fail (FOLF). The buffers are meant to absorb losses not only in going concern but also in gone concern situations. Therefore, it is essential that own funds are not depleted before resolution or liquidation is commenced. The Banking Unions core principle of no bail-out must be respected, and investors of the failing bank, not outsiders, should bear the losses in full. That being said, FFI is worried about certain elements of the proposal which abandon the no bail-out principle. The elements once again introduce the practice of bail-out and hence render the whole proposal flawed and dysfunctional. While the Banking Union was supposed to alleviate or even abolish the problem of moral hazard, the Commissions proposal contains elements which in fact reinforce it. The main one of these is the use of Deposit Guarantee Schemes (DGSs) as a bail-out instrument to cover losses investors have taken to make profit. The need to use DGSs as a bail-out instrument arises from the Commissions assumption that some banks cannot raise enough loss absorption capital to be eligible for the Single Resolution Fund. It seems to imply that the banks in question do not have viable businesses: a viable bank would be able to gather enough loss absorption capital by itself, and thus the DGS would not be needed to cover investors losses. The crisis intervention and DGS framework could, however, be built so as not to contain moral hazard or the element of bail-out. In fact, the current proposal contains elements that are headed in the right direction to make the framework workable. The development of the framework should focus on placing the losses fully on investors, which can be done by the timely launch of resolution or liquidation measures. This requires sufficiently clear supervisory powers and obligations so that the asset quality and the true amount of own funds of a FOLF bank can be ascertained early enough before the bank breaches the minimum capital requirement. The calculation rules for FOLF assessment should be drafted. The final moment for the FOLF decision should be when the minimum capital requirement is breached based on the materially ascertained balance sheet values. Fire sales of bank assets should be avoided: they destroy asset value and cause unnecessary losses to the FOLF bank. One way to avoid this is to transfer the covered deposits and a corresponding amount of assets to a healthy bank. The remainder of the bank can be liquidated in due course if a suitable buyer is not found. The failed bank then exits the market. To facilitate this kind of semiprivate solution, the acquiring bank should be allowed to use the franchise of the failed bank for a limited period to avoid unnecessary turmoil and uncertainty in the market and to give the acquiring bank time to absorb the acquired assets into its existing business. There is a risk that, after the transfer of assets and covered deposits, some of the customers may want to withdraw their deposits from the acquiring bank. Since the transferred assets may be impossible to liquidate in a short time without material haircuts, the DGS could offer the acquiring bank temporary liquidity support in the form of a repayable loan to pay for the withdrawals and thus mitigate the liquidity risk the acquiring bank could face. For these measures to work it is necessary that DGSs do not guarantee other deposits than those now covered by deposit insurance. In general, FFI opposes any extensions to the scope of deposit protection since this would weaken the DGS framework instead of making it stronger.
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Finance Finland slams EU investment rules as harmful price intervention

28 Aug 2023
Topic — A legislative package designed to increase retail investor confidence and participation in capital markets.
Message — The group wants to focus on information clarity and avoid detailed price regulations. They argue that strengthening supervision is more effective than introducing market-hindering rules.123
Why — This would reduce compliance risks and prevent mandatory changes to existing sales processes.45
Impact — Consumers lose access to diverse products and personalized advice due to cost-focused regulations.67
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Meeting with Sirpa Pietikäinen (Member of the European Parliament)

31 May 2023 · Topical EU financial legislation

Meeting with Ville Niinistö (Member of the European Parliament)

30 May 2023 · Financial sector

Meeting with Axel Voss (Member of the European Parliament, Shadow rapporteur) and BUSINESSEUROPE and

8 Mar 2023 · Corporate Sustainability Due Diligence

Meeting with Sirpa Pietikäinen (Member of the European Parliament)

1 Feb 2023 · Retail Investment Strategy

Meeting with Alviina Alametsä (Member of the European Parliament)

9 Dec 2022 · Finnish healthcare, equality in banking, considering mental health in insurance policies

Meeting with Ville Niinistö (Member of the European Parliament, Shadow rapporteur)

10 Nov 2022 · CRR/CRD basel implementation (staff level)

Meeting with Eero Heinäluoma (Member of the European Parliament, Shadow rapporteur)

29 Sept 2022 · Solvency

Meeting with Alviina Alametsä (Member of the European Parliament)

31 Aug 2022 · The relationship between values and economies

Meeting with Alviina Alametsä (Member of the European Parliament)

12 Jul 2022 · General Stakeholder Dinner

Response to Review of EU rules on payment services

8 Jul 2022

Yhtenä PSD2 tavoitteista oli maksamisen turvallisuuden parantaminen vahvan tunnistamisen avulla. Sen käyttöönotto osoittautui ennakoitua vaikeammaksi ja sääntelyn voimaantuloa jouduttiin lykkäämään vuoden 2020 loppuun saakka. Tietoa vahvan tunnistamisen vaikutuksista maksamisen turvallisuuteen on siis kertynyt vasta lyhyeltä ajalta. On myös huomattava, että sääntelyssä on paljon poikkeuksia vahvan tunnistamisen vaatimuksesta. Kannatamme EBA:n linjausta siitä, että poikkeusten käyttöönotto on tilipankin harkinnassa. Muu vaihtoehto ei ole mahdollinen niin kauan, kuin tilipankilla on ensi- ja viimekätinen vastuu oikeudettomien maksutapahtumien korvaamisesta asiakkaalle. On myös huomattava, että vaikka asiakas voisikin saada korvauksen pankiltaan, tuottavat oikeudettomat maksutapahtumat aina ylimääräistä huolta ja vaivaa. Pankit ovatkin edenneet poikkeusten käyttöönotossa järkevää varovaisuutta noudattaen. PSD2 tavoitteena oli myös tuottaa maksupalvelujen hyödyntäjille uusia, innovatiivisia palveluita edulliseen hintaan. Uusia innovatiivisia palveluita ei varsinkaan Suomessa ole vielä juurikaan nähty vaan maksunkäynnistyksessä ovat perinteiset toimijat siirtyneet sopimuspohjaisista, maksullisista pankkiliittymistä ilmaisten PSD2-rajapintojen käyttöön. Pankkien tiedossa ei ole, onko tämä vaikuttanut esim. kauppiaiden maksupalveluistaan maksamiin hintoihin. Sääntelyssä omaksuttiin alun perin lähtökohta, että PSD2 mukaisten API-rajapintojen määrittely ja rakentaminen tapahtuu markkinaehtoisesti. Tämä johti siihen, että syntyi useampia markkinastandardeja ja näiden muunnelmia. API-rajapintojen hyödyntäjien oli siis rakennettava erilaisia integraatioita eri tilinpitäjiin nähden. Vaikka tällainen useamman eri integraation tilanne ei ole optimaalinen, ei lisäsääntely yhden standardin luomiseksi tässä vaiheessa ole tervetullutta. On huomioitava, että integraatioiden vaatimat investoinnit on jo tehty. Lakisääteinen yksi standardi aiheuttaisi sen, että investoinnit jouduttaisiin tekemään uudestaan. Mahdollisen yhden standardin kehittäminen tulee jättää markkinoiden tehtäväksi. Sellainen kehittyy ajan kuluessa, mikäli se katsotaan liiketoiminnallisesti kannattavaksi ja siihen liitytään siinä tahdissa kuin se toimijoiden kannalta on järkevää. API-rajapintojen kautta tarjottavien palveluiden sääntelyä tulee myös muuttaa. Malli, jossa tilinpitäjäpankkien on rakennettava kaikki uudet toiminnallisuudet ja palvelut myös PSD2-rajapinnan kautta tarjottavaksi, on erittäin raskas ja lisää kehittämisen kustannuksia kohtuuttomasti. Tämä on voi rajoittaa tilinpitäjien mahdollisuuksia uusien palveluiden kehittämiseen ja aiheuttaa kilpailun vääristymistä sekä tuottaa vähemmän kuluttajia hyödyttäviä innovaatioita. PSD2-sääntelyn perusperiaate on, että asiakas eli tilinomistaja tekee sopimuksen palveluntarjoajan kanssa ja antaa tälle suostumuksensa tilille pääsyyn API-rajapinnan kautta. PSD2 rajapintojen kautta siis on tarkoitus jakaa sama tieto, joka on asiakkaan saavutettavissa pankin tarjoamassa verkkopalvelussa. Euroopan tietosuojaviranomainen EDPB on kuitenkin omassa ohjeessaan omaksunut tästä lähtökohdasta poikkeavia näkemyksiä. Ristiriita kahden eri valvojan ohjeistuksen välillä asettaa pankit erittäin hankalaan tilanteeseen, koska molemmilla niistä on toisistaan riippumaton oikeus määrätä sanktioita. Käytännössä PSD2 API-toiminnallisuuksien muokkaaminen mahdollistamaan EDPB:n ohjeen mukainen tietojen suodattaminen veisi järkevyyden esim. PSD2 mukaiselta tilitietopalvelulta. Mikäli tilitietopalveluun tuotaisiin suodatettua tietoa, jäisi tietoja, esim. maksunsaajien nimiä, puuttumaan maksutapahtumilta, jolloin tiedon käytettävyys rapautuisi. PSD2 ja GDPR välinen suhde tulisikin PSD2 uudelleentarkastelun yhteydessä kirkastaa.
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Meeting with Ville Niinistö (Member of the European Parliament, Shadow rapporteur)

30 Jun 2022 · CRR/CRD and basel implementation

Meeting with Sirpa Pietikäinen (Member of the European Parliament)

29 Jun 2022 · Basel III

Response to Open finance framework

28 Jun 2022

Finance Finland (FFI) supports efforts towards fair data sharing in which the treatment of different players is based on a true level playing field and reciprocity. The focus of opening up data should not be solely on the financial sector, but broadly on all sectors of society. Data access, sharing and usage should be considered in a broad context, with focus on cross-sectoral data sharing, i.e. the data economy. Taking this to account, any mandatory framework for open finance and new data access rights shouldn’t be introduced as these may turn out be ineffective and only lead to further fragmentation. FFI finds it important that the impact, costs and benefits of the revised Payment Services Directive (PSD2) are carefully and comprehensively assessed and analysed before any decisions on the wider opening up of financial data are made. As several weaknesses and challenges in the PSD2 have been recognized, any new initiative in the area of data sharing should not be based on the PSD2 framework as such. For example, data protection and security related issues must be carefully considered and solved before introducing legislation regarding data sharing beyond PSD2. This also applies to questions regarding the responsibilities and liabilities between different actors. However, we believe that promoting a data-driven financial sector is valuable. Consent-based data sharing could be beneficial and create added value for businesses and consumers in the form of new digital and innovative financial services if considered from a holistic perspective. Data generated by the commerce and e-commerce sectors, data regarding the value of housing company shares or real property, data collected by vehicles, ESG reporting data and real-time accounting data of businesses as well as taxation data can be mentioned as examples of such potentially relevant data that might enable the financial sector to provide better products and services for its customers. In Finland, we have already seen the digitalisation of housing trade in collaboration between private and public sector. The DIAS trading platform combines relevant data from different sectors and data holders, such as banks and estate agencies, and thus enables digital housing trade. Additionally, the Finnish pension insurers have been forerunners in developing digital pension tracking tools that are widely deployed by Finnish citizens and different service providers. Hence, we believe that there will be willingness to give access, share and use data on a voluntary and contractual basis if there is a real customer need for it and it is backed up by a market mechanism. Thus, businesses’ role in developing practices is crucial. The industry should have a role when establishing standards and common specifications and developing model contracts. A mandatory framework for data sharing would require significant investments in technical infrastructure and compliance. We are concerned that these kinds of obligations would hinder the possibilities to develop other digital services that could potentially create more benefits and value for customers. This is the case especially, if opening up the data is not compensated in a fair manner. ‘Data free of charge’ rarely creates a market mechanism. Finally, it is highly important that any open finance initiative is compliant with the data protection regulation and consumer protection principles. Customers must have absolute confidence in the security of their data, full control over the data being shared and the right to determine to which services and under what conditions their personal data will be used. Data that constitutes trade secrets or other business sensitive information should not be subject to data sharing, so only observed data should be shared.
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Response to Central securities depositories – review of EU rules

25 May 2022

For the most part, the amendment proposals related to settlement discipline benefit the sector because they harmonise the operating principles of market participants from different markets. They also promote the simultaneity of securities trade and related payments, which will improve investor protection and reduce the risks of market participants. 1 Settlement discipline – buy-ins The proposed changes related to settlement discipline are positive for the most part. The two step approach that postpones the implementation of mandatory buy-ins is also supportable, although the sector considers it would be more sensible to remove the provisions on buy-ins from legislation altogether. The use of buy-in involves significant challenges for the sector, however, because the conditions for initiating the process are unclear. Buy-ins also stands in the way of a level playing field for end-customers, so removing the entire mechanism from regulation would be sensible at this stage. Settlement discipline involves two important issues that must be solved. Firstly, buy-ins should be limited only to liquid securities. Buy-ins of illiquid securities could be difficult in terms of their availability, so these should be ruled outside of the buy-in mechanism. It would be easier to resolve the failed settlement of illiquid securities with monetary contributions than with substitutive financial instruments, for example. Secondly, the concept of ‘trading party’ must be further clarified and specified: legislation now uses two terms, Participant and Principal, and does this inconsistently as only Participant has been precisely defined. EU trades are usually settled by a CSD through the CSD’s nominee accounts. In the Finnish practice, all investors have their own book-entry accounts, which means that the current interpretation of the legislation includes retail investors in the scope of settlement discipline, although their power to influence the settlement process is very limited. Furthermore, extending the buy-in mechanism to retail investors is not a viable solution because the buy-in process and the requirements it entails can be challenging for a retail investor. Buy-ins are also specified in the wrong place: they should be treated as a measure that takes place between the parties to the trade, not as part of the settlement process. Buy-ins currently involve practical challenges as well, because the number of market participants who provide buy-in services is small, and their selection of securities does not cover all the securities in the market. As a result, buy-in activity may not be available despite the regulations. 2 Settlement discipline – penalties Extending the scope of the penalties regime to retail investors is not sensible. The transactions initiated by retail investors are small in value but large in volume. The penalties related to settlement discipline have now been applied for a few months, and based on the sector’s experience, the euro amounts of retail investors’ cash penalties are very small, ranging from a few cents to a few euros. Penalties this small have no significant effect on improving or maintaining the settlement ratio. The processing of small cash penalties causes unnecessary administrative burden on banks in the form of reconciliations, cash transactions and supervisory reporting. 3 The calendar of penalties The reporting and calendar of penalties and the statement and charging of cash penalties must adhere to a common EU calendar. In the present situation, differences in national holidays and non-banking days cause additional difficulties and work especially for investors and market participants who operate in the markets of more than one country.
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Finance Finland warns sustainability rules create uninsurable legal risks

23 May 2022
Topic — Consultation on mandatory due diligence for companies regarding human rights and environmental impacts.
Message — The association demands the removal of civil liability and damage payment provisions to prevent legal uncertainty. They also call for excluding investments and regulated financial services from the directive's scope.123
Why — This would exempt financial firms from complex monitoring duties and reduce costly litigation risks.45
Impact — Impacted communities and individuals would lose mandatory rights to compensation for corporate human rights failures.67
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Meeting with Sirpa Pietikäinen (Member of the European Parliament)

20 May 2022 · EU Taxonomy, CSRD, Basel, AIFMD ja ELTIF

Meeting with Othmar Karas (Member of the European Parliament, Shadow rapporteur) and Finance Denmark and Finance Sweden

18 May 2022 · Reform der EU-Bankenregulierung (CRR3/CRD6)

Meeting with Emil Radev (Member of the European Parliament, Rapporteur) and Finance Denmark

18 May 2022 · AML

Meeting with Ville Niinistö (Member of the European Parliament, Shadow rapporteur)

28 Apr 2022 · banking package and other current topics - staff level

Meeting with Karolin Braunsberger-Reinhold (Member of the European Parliament, Shadow rapporteur) and Finance Denmark and

22 Apr 2022 · AMLR

Meeting with Luis Garicano (Member of the European Parliament, Rapporteur) and Finance Denmark and Finance Sweden

3 Mar 2022 · Meeting with stakeholders

Meeting with Tommy De Temmerman (Cabinet of Commissioner Mairead Mcguinness) and Nordea Bank Abp and

9 Dec 2021 · Basel III

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis)

16 Nov 2021 · Basel III, Banking Union, Solvency II

Meeting with Jutta Urpilainen (Commissioner)

16 Nov 2021 · Sustainable finance; other current issues on their sector

Meeting with Tommy De Temmerman (Cabinet of Commissioner Mairead Mcguinness)

16 Nov 2021 · Basel III, Banking Union, Solvency II.

Meeting with Mairead McGuinness (Commissioner) and

12 Nov 2021 · Introduction of the Finnish financial Industry and Finance Finland.

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness) and Finance Denmark and

5 Nov 2021 · MiFID/MiFIR

Response to New EU system for the avoidance of double taxation in the field of withholding taxes

26 Oct 2021

Finance Finland welcomes the European Commission’s initiative to introduce a common EU-wide system for withholding tax on dividend payments. Complicated and different withholding tax processes form a substantial barrier to cross-border investments within the EU and it is important that withholding tax processes should be harmonized. We see that the best option to remove these tax-obstacles would be to establish a harmonized, common EU relief at source system that would be simple to operate with clear rules regarding processes and liabilities. Kindly find our more detailed comments attached as a pdf-file.
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Response to Revision of Non-Financial Reporting Directive

5 Jul 2021

Finance Finland (FFI) welcomes the Commission’s proposal to harmonise and standardise companies’ sustainability reporting. We are in favour of extending the reporting scope to large and listed companies, and to also include SMEs in the scope, although with more proportionate reporting obligations. SMEs operating in sectors where sustainability risks are particularly high, such as coal, oil and gas production, mining, and chemicals, should report according to the same standard as bigger companies. We highly advocate the proposal to digitalize the reporting, and to use the future European Single Access Point (ESAP) as publication venue to make the data freely available to everyone in the society. Our biggest concern about the proposal is about the practical implementation and timing of reporting. The timeline that the Commission has set up is extremely ambitious, and other sustainable finance regulations have not been finalized with such speed so far. It is essential that companies are given sufficient implementation time even if the preparation of standards gets delayed. This should be done in practice by making the date of application dependent on the date of finalisation of the first sustainability reporting standard. Second, it needs to be noted that the financial sector’s sustainability reporting will be based on non-financial companies’ reports, and therefore there will be an inevitable difference in publication time between the two. A practical solution would be to sequence the publication time of non-financial and financial companies, so that it is ensured that financial companies get the data needed for their own reports. Because of this time lack, it should be left to companies’ own discretion whether they want to include the sustainability information in the management report or to publish it as a separate report. Alignment with existing sustainable finance regulations, taxonomy and SFDR, is necessary so that the sustainability reports can be used in a meaningful way. We expect the CSRD to become an important data source for the financial companies to fulfil their disclosure obligations stemming from the SFDR. Existing widely used voluntary reporting standards, such as TCFD and SASB, should be integrated into the EU’s sustainability reporting standard. This way the market would not need so many overlapping standards over time. Since the proposal is for a directive, attention should be given to ensure that the implementation and interpretation of it will be the same in all EU Member States. There are certain terms and concepts that require specification to ensure this. First, it needs to be clear what “limited assurance” requires from companies in practice and made clear that the assurance obligation concerns only the sustainability information in the management report. It should also be specified what it entails for the taxonomy article 8 reporting, since the assurance obligation is extended to that as well. Second, the reporting time horizons, now written as “medium-term” and “long-term”, should be defined in years. Third, banking and insurance sectors do not use the term “turnover”, so it needs to be translated in an applicable way to these sectors. In accordance with the proportionality principle, English should suffice for the sustainability reports of subsidiaries of groups, so that they will not have to translate their sustainability reports into all the languages of all subsidiaries.
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Meeting with Jutta Urpilainen (Commissioner)

23 Jun 2021 · Upcoming legislative agenda concerning financial services.

Response to Commission Delegated Regulation on taxonomy-alignment of undertakings reporting non-financial information

2 Jun 2021

Finance Finland welcomes a phased approach where more detailed KPIs would be disclosed 2023 but emphasizes that financial undertakings’ (FU) disclosures should occur with a sufficient time lag following the disclosures of financial and non-financial clients and counterparties, for both first-time and ongoing disclosures. We suggest 1 year for first time adoption and a quarter on an ongoing basis. The application of Art. 8 and the Delegated Acts (DA) overlaps with the introduction of other regulation. Based on the draft, it seems FUs would have to disclose information on their clients before the details of CSRD-reporting are fully known. Also, the timeline should reflect the fact that large FUs may already have to report the GAR within Pillar III by early 2023, despite non-financial companies (NFCs) starting to report KPIs simultaneously. SFDR disclosures (starting early 2022) will have similar challenges. With entry into force too close to application of the reporting obligation, implementing changes to reporting would be challenging. The granular templates and timely inclusion of NFC data in Management Reports under CSRD will pose challenges for FUs. We question the usability of the 2022 taxonomy eligibility assessment, also because from art.11.2 and without further clarification, the required content and format for the 2022 disclosures would remain unclear, likely causing comparability issues. Large parts of the investments of asset managers and investment firms, and parts of lending, are to non-EU countries, meaning that for those assets, even after 2022, no taxonomy information will be available. The KPIs for taxonomy-aligned percentages may vary a lot amongst certain FUs, causing comparability issues. Regarding the stock, it should be clear from which point in time onwards information shall be collected. It should be ensured in art.9.3 that no retrospective requirements concerning reporting periods prior to the introduction of KPI disclosures in 2023 are created. Also, much of the required granular data is difficult to obtain for FUs; starting in 2023 with just some key breakdowns, a simpler set of KPIs for GAR, focused on lending and investments, with GIR and AUM for asset managers, would thus be reasonable, as data would then be more readily available from NFCs’ disclosures. We also suggest starting with banking book GAR, excluding the trading book (the purpose of which is unclear), and further excluding exposures to other FUs until clearer methods for their inclusion are in place. We also consider many of the areas listed in Fees and Commissions to be of limited relevance. We note that excluding certain exposures from the GAR nominator while including them in the denominator would affect the KPIs and their usability negatively; also, exposures to undertakings not subject to the CSRD would thus unjustifiably be a major degrader of the KPIs at least until 2025. We suggest that the KPI for investment activities in insurance companies should be based only on taxonomy-eligible investments where the insurer controls the investment decision. The following activities should be excluded from the nominator and denominator of the KPI: investments where the policyholder makes the choice of where to invest (as a secondary KPI), exposures to undertakings not subject to the CSRD, non-EU exposures and derivatives. We welcome the fact that FUs would only be required to analyse the taxonomy-alignment of client activities subject to reporting under the NFRD/CSRD. However, the draft annexes seem to include “add-on” portfolios to this general scope, including non-NFRD exposures to SMEs and retail customers. e.g. RRE-lending and credits for consumption for cars; here, we ask the EC to clarify its intention and rationale. Regarding the need to provide forward-looking information, referenced in several parts of the DA, we would propose removing this from it, seeing this as better suited for and already captured in the CSRD.
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Response to EU single access point for financial and non-financial information publicly disclosed by companies

15 Jan 2021

• Finance Finland welcomes the European Commission’s plan to streamline company reporting (both financial and non-financial) in the EU. We have called for a centralized ESG data register and think that accessibility to sustainability data should be the priority in building ESAP. • Second objective for ESAP should be that companies’ reporting gets easier, instead of making it yet another recipient of financial or non-financial reporting that would only add to companies’ administrative work. • Third, a proper administration for ESAP needs to be ensured. It should be operated by a public entity or a public-private partnership to prevent a situation of private monopoly. We support open access to ESAP for different members of society, and the data should be available for free or at a reasonable cost. The increased demand and need for ESG data, stemming in part from market developments on the one hand, and regulatory demands on the other, has led to a situation where financial sector is in urgent need for a system that ensures access to that data. While we support streamlining reporting of both financial and non-financial content, the need for non-financial public data is more critical, as we currently lack any system for its EU-wide distribution. The taxonomy regulation and the future updated non-financial reporting directive provide a natural foundation for reporting to ESAP, but we also want to stress the data needs created by the sustainability disclosures regulation. ESAP should be a tool for financial sector to comply with the sustainable finance regulations. Companies already face several overlapping reporting obligations on the financial reporting side. ESAP should not add to that but ensure that the existing reporting channels assemble the data to a single register, ESAP. It should be considered whether ESAP could eventually lead to decreasing of parallel financial reporting. The build-up and management of ESAP could be done by an EU statistical center or by a public-private partnership. The register is intended to serve both public and private needs, so most of its funding should come from the EU’s budget. For the data to be truly available to all interested parties, it should be offered for free or at a reasonable cost. ESAP should be open to companies outside the EU as well, having potential to develop into a global (ESG) data platform if companies outside the EU would adopt the same sustainability reporting standards.
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Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

The proposed climate mitigation criteria for existing building stock would in effect mean that in many countries sustainable infrastructure investments or lending would no longer be possible (according to the taxonomy criteria). The Commission proposes that only buildings that have Energy Performance Certificate level A could be considered sustainable, but the criteria for granting an EPC level A for buildings varies significantly between the EU Member States. Only about 1% of buildings in Finland have that rating, and there is not a single green bond in Europe that would qualify if this criterion would become effective. The TEG’s original proposal for buildings’ energy efficiency should be restored, which is that the top 15% most energy efficient among local stock would be eligible. This criteria would set the same ambition level for different markets, whereas the single EPC level does not, while allowing for the eligibility criteria to tighten over time as buildings reach higher levels of efficiency. Also, more precision must be given to the ‘do no significant harm’ (DNSH) criteria for buildings. In the delegated act proposal, a building should not be built on arable, crop or forest land (whether covered by trees or not). This kind of vague description could mean that there is no land in Finland that would be eligible as building site. It needs to be specified what constitutes crop land and what is forest, as the understanding of these concepts can be very different depending on country. The DNSH criteria on acquisition and ownership of buildings also needs a time frame for determining when enough time has passed since the land use change from crop or forest land to a building site. Without determining such a time frame, we can hardly imagine any buildings that would be taxonomy eligible. Demand for “additionality” in forestry does not make sense in areas where sustainable forest management is a standard. The Commission proposes to exclude ordinary sustainable forest management from the taxonomy criteria, contrary to the TEG’s advice. The Commission’s request for “additionality” in forest management mean that only measures above or beyond some kind of "ordinary" forest management can be classified as sustainable. As these measures are only marginal in comparison to the ordinary sustainable forest management, the climate benefit will also be marginal. In Finland, 90 % of forests used for commercial purposes are PEFC-certified . This means that sustainable forest management is a standard here. It does not make sense to exclude a sustainable economic sector entirely only because it is “too sustainable”, meaning that instead of sustainable forest management being something exceptional, or “additional”, it is normal business conduct. The Commission’s taxonomy proposal does not encourage sustainable forestry developments, but instead aims for a situation where sustainable forestry can only be and remain marginal in the EU. We strongly advocate for the removal of all “additionality” conditions from the taxonomy Annex I forestry criteria. Alignment with Paris agreement should be the primary basis for taxonomy criteria. However, not all criteria are about GHG limits, and therefore for them it is not necessarily possible to use the Paris agreement as benchmark. For those remaining criteria to be usable as guidance in investment decisions, we think it would be reasonable that in general at least 5-15 % of economic activities in the EU would be eligible. The criteria can and should be tightened over time, but we are worried that if it is too tight, it does not serve the intended purpose of use. For example, in the Commission’s proposed delegated acts the existing hydropower plants would, after application of strict do no significant harm criteria, be largely excluded, although they do not produce direct emissions and produce renewable energy.
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Response to Capital markets – research on small and mid-sized companies and fixed income (updated rules in light of the COVID-19 pandemic)

11 Sept 2020

Finance Finland (FFI) represents the majority of banks, insurers, finance houses, securities dealers, fund management companies and financial employers operating in Finland. It has 323 member organisations. Finance Finland is not in favour of the Commission's proposal for amendments to the unbundling rules described in the draft delegated directive. FFI sees that the scope of application is too limited. It would be appropriate to provide for the extension of this proposal to all companies irrespective of their market capitalisation value, not only small and mid-cap companies. Authorising the bundling of SME research alone is not practical and probably will not increase SME research. Having two pricing models is complicated for both investment firms and their clients and will cause confusion. It is very unlikely that this initiative will be an incentive to increase research coverage of SME companies. There might be challenges to the clients to accept the re-bundling of research payments to their commission rates.
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Response to Strengthening the consideration of sustainability risks and factors for financial products (Directive (EU) 2017/593)

6 Jul 2020

Finance Finland's (FFI) response to the Commission’s draft amendments on the integration of sustainability considerations into MiFID II • The definition of ESG-compliant products should not be narrowed under MiFID. The definition of sustainability preferences should refer to the existing categories of sustainable products in Article 8 and 9 SFDR without adding the further qualifications proposed as sub-points (i) and (ii) of Article 1 (5). It should be possible to take into account the customer's sustainability preferences also in situations where the customer would prefer a product that promotes environmental or social characteristics even if said product would not fulfil the qualifications set out in sub-points (i) and (ii) of Article 1 (5). • The inclusion of principal adverse impact in SFDR is targeted at the entity rather than the product. Due to that the considerations of product-level principal adverse impact should be deleted. • The definition of sustainability preferences refers to “financial instruments” and not “financial products”, which is the term used in SFDR. As a result, the rules of the proposed regulation could be interpreted as inclusion of instruments, as defined in section C of the MiFID II Directive, for which issuers or financial market participants do not have obligation to disclose information under SFDR, e.g. bonds and shares. It would also include derivatives and other financial instruments used for the purpose of hedging and not for investment purposes. This will lead to implementation challenges. The proposed wording would be detrimental not only to the investor but also to issuers, since a considerable share of investment opportunities might be impossible to include. It is unclear how the proposed regulation would be applied to derivative contracts, in particular OTC derivatives, if it is possible at all. FFI is seeking clarification from the commission to the definition of suitability preferences. In addition to this, FFI is advocating for exclusion of financial instruments for hedging purposes, especially OTC derivatives, from the proposed regulation and the definition of sustainability preferences. • It is stated in the recital (5) that “investment firms providing investment advice should first assess the investor's’ investment objectives, time horizon and individual circumstances, before asking their clients for their potential sustainability preferences”. We understand this so that the potential sustainability preferences should not outweigh the investor’s other investment objectives, time horizon and individual circumstances. • Used terminology should be coherent. In the proposals the terms “any”, “potential” or “his or her” sustainability preferences are used instead of “sustainability preferences”. We advise to use only the term “sustainability preferences” in order to avoid confusion. • FFI welcomes the implementation period of 12 months in order to have sufficient time to implement the rules after they are finalised. However, it is unclear how this implementation timeframe fits together with the requirements of the sustainability disclosures under Regulation (EU) 2019/2088, which should apply from 3/2021. • Finance Finland promotes the response given by EBF and Efama on this topic. See proposed amendments from the attachment.
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Response to Strengthening the consideration of sustainability risks and factors for financial products (Regulation (EU) 2017/565)

6 Jul 2020

Finance Finland's (FFI) response to the Commission’s draft amendments on the integration of sustainability considerations into MiFID II • The definition of ESG-compliant products should not be narrowed under MiFID. The definition of sustainability preferences should refer to the existing categories of sustainable products in Article 8 and 9 SFDR without adding the further qualifications proposed as sub-points (i) and (ii) of Article 1 (7). It should be possible to take into account the customer's sustainability preferences also in situations where the customer would prefer a product that promotes environmental or social characteristics even if said product would not fulfil the qualifications set out in sub-points (i) and (ii) of Article 1 (7). • The inclusion of principal adverse impact in SFDR is targeted at the entity rather than the product. Due to that the considerations of product-level principal adverse impact should be deleted. • The definition of sustainability preferences refers to “financial instruments” and not “financial products”, which is the term used in SFDR. As a result, the rules of the proposed regulation could be interpreted as inclusion of instruments, as defined in section C of the MiFID II Directive, for which issuers or financial market participants do not have obligation to disclose information under SFDR, e.g. bonds and shares. It would also include derivatives and other financial instruments used for the purpose of hedging and not for investment purposes. This will lead to implementation challenges. The proposed wording would be detrimental not only to the investor but also to issuers, since a considerable share of investment opportunities might be impossible to include. It is unclear how the proposed regulation would be applied to derivative contracts, in particular OTC derivatives, if it is possible at all. FFI is seeking clarification from the commission to the definition of suitability preferences. In addition to this, FFI is advocating for exclusion of financial instruments for hedging purposes, especially OTC derivatives, from the proposed regulation and the definition of sustainability preferences. • It is stated in the recital (5) that “investment firms providing investment advice should first assess the investor's’ investment objectives, time horizon and individual circumstances, before asking their clients for their potential sustainability preferences”. We understand this so that the potential sustainability preferences should not outweigh the investor’s other investment objectives, time horizon and individual circumstances. • Used terminology should be coherent. In the proposals the terms “any”, “potential” or “his or her” sustainability preferences are used instead of “sustainability preferences”. We advise to use only the term “sustainability preferences” in order to avoid confusion. • FFI welcomes the implementation period of 12 months in order to have sufficient time to implement the rules after they are finalised. However, it is unclear how this implementation timeframe fits together with the requirements of the sustainability disclosures under Regulation (EU) 2019/2088, which should apply from 3/2021. • Finance Finland promotes the response given by EBF and Efama on this topic. See proposed amendments from the attachment.
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Response to Integration of sustainability risks and factors in relation to insurance undertakings and insurance distributors

2 Jul 2020

• The proposed amendments to 2017/2358/EU should only apply to products with an investment purpose (e.g. insurance-based investment products), not all insurance products. All insurance products include risk insurance products such as home, health or vehicles insurance, where sustainability preferences are often irrelevant. • Insurance undertakings should not be required to consider sustainability factors in the product approval process of all insurance products, but only if the insurance product is to be advised or sold to customers with sustainability preferences. • The definition of sustainability preferences should refer to the existing categories of sustainable products in Article 8 and 9 SFDR without adding the further qualifications proposed as sub-points (i) and (ii) of Article 2 (4). It should be possible to take into account the customer's sustainability preferences also in situations where the customer would prefer a product that promotes environmental or social characteristics even if said product would not fulfil the qualifications set out in sub-points (i) and (ii) of Article 2 (4). • Finance Finland promotes the response given by Insurance Europe on this topic. For more details, see the attachment.
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Meeting with Jyrki Katainen (Vice-President) and Finance Denmark and

14 May 2019 · Basel Implementation

Meeting with Olivier Guersent (Director-General Financial Stability, Financial Services and Capital Markets Union) and Finance Denmark and Finance Sweden

14 May 2019 · The finalization of Basel IV, and the European implementation of the new Basel requirements.

Meeting with Olivier Guersent (Director-General Financial Stability, Financial Services and Capital Markets Union)

9 Apr 2019 · Sustainable Finance

Meeting with Andrea Beltramello (Cabinet of Vice-President Valdis Dombrovskis)

9 Apr 2019 · Solvency II, Sustainable Finance

Meeting with Nathalie De Basaldua Lemarchand (Cabinet of Vice-President Jyrki Katainen)

28 Sept 2018 · General discussion of financial services topics.

Response to REFIT review of the Motor Insurance Directive

24 Jul 2018

Joint statement of Finnish Motor Insurers’ Centre and Finance Finland regarding Proposal for a Directive amending Directive 2009/103/EC (Please, see the attachment.)
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Response to Initiative on an integrated covered bond framework

16 May 2018

We welcome the opportunity to give feedback on the Commission’s initiative on an integrated covered bond framework. We appreciate that the Commission has noted the well-functioning markets in many member states and keeps the harmonisation as principle based. Covered bond funding is especially important for Nordic countries. In Finland, roughly one third of mortgage loans are funded by covered bonds. It has proved to be a stable funding source with historically low loss ratios, even during financial stress. We support the Commissions aim to enhance the use of covered bonds as a stable and cost-effective source of funding for credit institutions. We would like to particularly highlight the importance of cost-effectiveness. In Finland, also small banks issue covered bonds. Thus, it is especially important not to increase the fixed costs for issuers to keep the small players in the market as well. Even though we find the proposal balanced overall, we think there are certain risks which might hamper the well-functioning and cost-efficient market we have today. Please find more detailed comments attached.
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Meeting with Andrea Beltramello (Cabinet of Vice-President Valdis Dombrovskis)

15 May 2018 · SME listing, sustainable finance

Meeting with Olivier Guersent (Director-General Financial Stability, Financial Services and Capital Markets Union) and Finance Denmark and Finance Sweden

8 Nov 2017 · Basel

Meeting with Marlene Madsen (Cabinet of Vice-President Jyrki Katainen)

7 Nov 2017 · Sustainable Finance, Banking Union and ESA Review

Meeting with Tatyana Panova (Cabinet of Vice-President Valdis Dombrovskis)

9 Mar 2017 · ESAs, PRIIP

Meeting with Jyrki Katainen (Vice-President)

15 Nov 2016 · The Basel IV joint position paper

Meeting with Jyrki Katainen (Vice-President)

14 Jan 2016 · Panel discussion on future of EMU

Meeting with Mette Toftdal Grolleman (Cabinet of Commissioner Jonathan Hill)

13 Apr 2015 · Introductory meeting

Meeting with Juho Romakkaniemi (Cabinet of Vice-President Jyrki Katainen)

13 Apr 2015 · Capital Markets Union, European Fund for Strategic Investment