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Suomen pörssisäätiö (the Finnish Foundation for Share Promotion)

The Finnish Foundation for Share Promotion (Suomen pörssisäätiö) is a neutral public interest non-governmental organization promoting retail investments in shares and other securities as well as promoting functioning of the capital markets with a special focus on retail investors.

Lobbying Activity

Response to Recommendation on savings and investment accounts

24 Jun 2025

About us: We are independent non-profit foundation promoting retail investment and capital markets in Finland. Background: We highly welcome the Commissions initiative to issue a recommendation on European savings and investment accounts. This should be the first step towards a pan-European investment account with tax incentives governed under European regulation. We strongly encourage the Commission to investigate Finnish legislative framework concerning the Finnish equity savings account (hereinafter FIN-ESA). The acts governing FIN-ESA came into force early 2020. Since then, more than 400 000 Finns have opened the account. For context, the Finnish population is 5.6 million. Also, approximately 1 million Finns are shareholders owning equities of publicly traded companies. The popularity of investing continues to rise. Thus, Finland has a strong retail investment culture. The Finnish Equity Savings Account: Main characteristics of the FIN-ESA are the following: - The FIN-ESA is, actually, an account containing two accounts. Firstly, it contains a cash account similar to bank accounts. Secondly, it contains a book-entry account for equities issued by publicly traded companies. - Only certain financial instruments can be held in the FIN-ESA. Available financial instruments are shares (equities) of publicly traded companies. Publicly traded companies are defined as companies that are subject to trading in a European regulated market, SME growth market or multilateral trading facilities. Also, equities traded in similar third country marketplaces are allowed. - Only a natural person can open a FIN-ESA. - The FIN-ESA is transferable from one service provider to another. - The FIN-ESA has strong tax incentives. Taxation of dividends and capital gains is deferred until one withdraws assets from the FIN-ESA. Retail investors can thus fully enjoy the effects of the compound interest phenomenon as the so-called tax wedge does not decrease dividends or other capital gains. Secondly, this means that the FIN-ESA is a convenient way to start investing as one does not have to factor in the effects of taxation. Please see attached pdf for illustrative picture. Our vision for the European Investment and Savings Account: 1. Taxation of the European Savings and Investment Account (hereinafter EUR-SIA) should be deferred until assets are withdrawn from the EUR-SIA (like the FIN-ESA). This would be a great incentive for retail investors to start long-term investing due to the fully functional compound interest phenomenon. In addition, selling equities and reinvesting assets would be easy as one does not have to take taxation into account. This has a negative impact on the state's tax revenue in the short term. In the long term, the difference evens out or the tax revenue even increases as savings are invested creating higher capital gains. When an individual makes a withdrawal from EUR-SIA the tax should be automatically calculated and withheld. An alternative approach would be to allow for limited annual investments that are not taxed at all (like UK-ISA). 2. The EUR-SIA should be transferable from one service provider to another. To enable this, available financial instruments in the EUR-SIA should be narrowed to shares (equities) of publicly traded companies and to ETFs. We point out that shares in funds (such as UCITS and AIF) may not be transferred from one custodian to another even in the same country. Focusing on publicly traded shares and ETFs the EUR-SIA may even be transferable from one service provider to another in a different Member State should custodian services and CSDs become sufficiently harmonized in the EU. This should be the ultimate goal as it supports the free movement of people (and their capital). 3. Only listed equity products should be allowed in the EUR-SIA as the EU desperately needs more equity investments. Starting with a narrow scope is recommended because it is easier to add products later than to remove th
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Response to Savings and Investments Union

6 Mar 2025

We are an independent non-profit organization promoting legislation and market practices that benefit retail investors ensuring that capital markets are safe and transparent platform for them. 1.Legislative action or some other tool?: The SIU is essential for creating efficient European capital markets, but we need more than legislative action to achieve this. The EU must boost the competitiveness of European companies to make them more attractive investments. 2.Look into Nordics: Low household participation in capital markets should be addressed. We urge the Commission to study the Nordic countries, where household participation in equity markets is higher than the EU average. By understanding their retail investment culture and practices, we can apply these successful strategies across the EU. 3.Improve financial literacy: Financial literacy should be promoted among all age groups, learning should start young, and the schools have a vital role. Without proper knowledge of investment opportunities and related risks, citizens are unlikely to participate in the capital markets. Financial literacy education should be provided by independent non-profits, such as in the Nordics, and incorporated in schools curriculums to ensure its objectivity. Increased financial literacy should never be an excuse for reducing investor protection. 4.Empowering households : Many European investment products for retail investors are costly and yield low profits. Instead of controlling where and how to invest, we should boost financial literacy, ensure that essential information is provided, and ensure robust fraud protection. We should recognize that risk and profit usually correlate. Rather than aiming for low risk, investors should understand and diversify their risks. Equity investments are generally suitable as long-term investments. Households be encouraged to invest directly in publicly traded stock and in equity based UCITS due to great cost and profit ratio. Debt instruments may be low-risk but typically cost more and yield lower profits than equity. Competitive measures should be introduced in the investment sector, from product development to distribution and advisory services, such as increasing fee transparency, simplifying disclosures, and reducing reporting burdens. Moreover, attending AGMs across borders remains difficult. Hybrid AGMs with full shareholder rights for remote participants should be encouraged for flexibility. This would promote retail investor participation in corporate governance as reliable long-term investors. 5.Integration of the financial market infrastructure: The fragmentation of trading and post-trading infrastructure is a characteristic of EU financial markets compared to the US. Additionally, trading venues, CSDs, and CCPs are supervised at the national level, which can create an uneven playing field. Also, the Commission should seek market-based options for mergers in the trading and post-trading sectors. 6.Improve uniform enforcement and supervision: We have moved towards a single rulebook doctrine, which require that same rules should be supervised and enforced in a uniform manner in the Union. The SIU should focus on uniform supervision and enforcement. 7.Clarify capital markets legislation while deepening integration of tax and insolvency law: The SIU should simplify the complex legislation while maintaining good investor protection. Future harmonization should address cross-border investment barriers in insolvency and tax law. Moreover, the current financial services landscape hinders EU citizens' mobility. Opening or retaining bank and investment accounts when moving between member states is challenging. Introducing an EU-wide investment account with tax benefits for retail investors should be considered, ensuring easy cross-border transfers. 8.Concluding remark: If the capital markets are a good place for retail investors to thrive, it also will be an excellent place for all market participants
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Response to Retail Investment Strategy

11 May 2021

We promote retail investment and develop the securities markets in Finland. Retail investment strategy is an important and highly welcomed initiative and we agree that the level of participation by European retail investors remains too low. Please see below for our comments about the roadmap: - Investor protection and disclosures rules differ between legislative instruments. These caps should be narrowed. For example, retail investors should be able to rely on that they are adequately and similarly protected and informed regardless of a financial instrument (e.g. there should not be differences between insurance-based investment products and other financial instruments). - Information provided for retail investors should be understandable, comparable, and material. Currently, key information documents tend to provide investors with non-comparable misleading information in some cases. - Digital innovation and the role of social media should be considered when the retail investment strategy is further developed. Aftermath of the financial crisis and Lamfalussy II legislative process has turned EU capital market law into a highly complex field of. Many retail investors and social media influencers are not familiar with or are unable to gather information about, e.g, market abuse rules (e.g. phenomenon like WallStreetBets & GameStop) or when social media activities may be deemed as investment advice under MiFID II. Clear and understandable guidance for EU citizens regarding this matter is needed. - We highlight the importance of financial literacy. EU citizens should have an equal access to proper financial literacy education regardless of their gender, ethnicity, or social background already at young age. As lack of financial literacy tend to create and maintain inequalities. - Differentiation between different investor categories should be approached with caution. The level of investor protection for retail investors should remain high regardless of possible new investor categories, but on the other hand legislator should not take too paternalistic approach. Classifying retail investors in different categories is a difficult task due to heterogenous investment goals, risk profiles and investment related know-how as personal wealth or a level of education do necessary not correlate with an investor’s risk profile or know-how. Should a new semi-professional investor class be created, it should be ensured that non-professional clients remain desirable for financial institutions. - Retail investors’ rights and their empowerment are important. Investor protection and financial literacy is only one side of the coin if we want to increase retail investors’ participance in the capital markets. Taking direct investments in publicly traded shares as an example. In Finland almost about fifth of the population owns directly publicly traded shares. The number of Finnish shareholders grew over ten percent during 2020. Thus, retail investors’ willingness to participate in the capital markets is rapidly growing, but they still face difficulties in participating in corporate governance. In the EU, COVID19 pandemic did not lead to a long-needed digitalization of annual general meetings and cross-border use of shareholder rights remains difficult. Retail investors usually have a long investment horizon, and they are generally interested in sustainable value creation. COM should launch initiatives, like a revision of the shareholders rights directive, aiming to empower retail shareholders. This kind of initiatives would support EU’s goals related to CMU, digitalization, and sustainable finance. Also, retail investors could become a key source of financing for companies if it would be easier to participate in IPOs and other equity issuances. Legislator should focus on improving SME growth markets, which is much more suitable marketplace for both, investors and companies, than e.g. crowdfunding platforms lacking liquidity and investor protection.
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