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OP Financial Group

OP Ryhmä

OP Financial Group’s mission is to promote the sustainable prosperity, security and wellbeing of its owner-customers and operating region.

Lobbying Activity

Meeting with Daniel Mes (Cabinet of Executive Vice-President Frans Timmermans), Diederik Samsom (Cabinet of Executive Vice-President Frans Timmermans) and

28 Feb 2023 · IRA package and GD Industrial Plan, EU Green Deal

Meeting with Thomas Woolfson (Cabinet of Executive Vice-President Margrethe Vestager) and Wärtsilä Corporation and

28 Feb 2023 · European competitiveness and the Green Deal Industrial Plan

Meeting with Jyrki Katainen (Vice-President)

20 Mar 2018 · Economic situation in Finland, EMU

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

30 Nov 2017 · Economic and Monetary Union (EMU), Capital Markets Union (CMU)

Response to Legislative proposal for an EU framework on crowd and peer to peer finance

27 Nov 2017

1. OP Financial Group supports the EU Action on Investment-based crowdfunding OP Financial Group welcomes the opportunity to comment the inception impact assessment preparing the legislative proposal for an EU framework on crowd and peer to peer finance. We limit our comments to investment-based crowdfunding. We have recently launched a crowdfunding platform operated by OP Corporate Bank. The legal framework behind the platform is based on domestic Investment Services Act that implements MiFID regime and sui generis Crowdfunding Act that clarifies disclosure and investor protection rules. Based on the new legal regime several Finnish banks and smaller MiFID licensed investment firms are engaged in crowdfunding. Furthermore, the legislation provides a light-touch registration or licensing for smaller start-up crowdfunding firms. Based on our positive domestic experiences, we suggest that the Commission adopts an evolutionary approach on EU regulation of crowdfunding. Regulatory and policy measures could combine both shorter and longer term initiatives. 2. A Comprehensive EU approach would enable platforms to scale-up cross-border and provide better consumer protection The policy objective of the Commission initiative, in the context of Capital Markets Union, is to enable crowdfunding activity to scale-up across national borders. Furthermore, new rules should provide effective risk management and consumer protection. We find that these policy objectives are best achieved with Option 3 and a comprehensive EU approach. When it comes to investment-based crowdfunding, we find that in the medium term the most natural way forward is targeted amendments to investment services (MiFID II) and issuer disclosure regime (Prospectus Regulation). Based on ESMA´s Advice and Opinion the investment-based crowdfunding is mainly classified as reception and transmission of client orders. This is the starting point of the domestic Crowdfunding Act as well. However, there has been some debate and uncertainty, what is the service offered vis-à-vis the company seeking crowdfunding? Is the MiFID licensed service provider only providing a platform for the company or does the service constitute the traditional underwriting of securities emission as well? The latter approach would clearly be disproportionate for smaller companies seeking alternative finance. Although the aim behind the domestic Crowdfunding Act is clear, we find that the role of investment firm as an operator of crowdfunding platform could be further clarified. The list of MiFID regulated investment services could be further developed to cover operation of crowdfunding platform as a new category of investment service. The introduction would be like evolution of bank and investment firm operated trading venues. The list of investment services was supplemented with operation of multilateral trading facility (MTF) in 2007 and organised trading facility (OTF) in 2014. In the shorter term the Commission and / or ESMA could issue interpretative guidance on regulatory treatment of investment-based crowdfunding to provide legal certainty for firms operating under MiFID license. Second important aspect that would require EU approach is issuer disclosure regime. The EU Prospectus Regime provides Member States with wide discretion on local disclosure. On the other hand, this approach is vital for domestic capital markets but it also constitutes potential barrier for crowdfunding to scale-up as disclosure regimes differ. We would highlight the need to develop a proportionate issuer disclosure regime for companies seeking crowdfund-ing. The Finnish Crowdfunding Act and supplementary Ministerial Degree provides a standardised template heavily inspired by EU Regulation on Packaged Investment Products (PRIIPs). This simplified disclosure could serve as a model for EU level disclosure as well.
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Meeting with Paulina Dejmek Hack (Cabinet of President Jean-Claude Juncker)

29 Sept 2017 · FinTech Action Plan

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

3 Nov 2015 · General Commission introduction