FIN-FSA Amends Rules and Guidelines on Reporting of Funding Plans
FIN-FSA amended regulations and guidelines 6/2014 on the reporting of funding plans and these will be effective from December 31, 2020. The regulations and guidelines have been amended to incorporate the updated EBA guidelines on harmonized definitions and templates for funding plans of credit institutions (EBA/GL/2019/05). Additionally, the FIN-FSA Board decided, at a meeting on June 29, 2020, that the countercyclical capital buffer (CCyB) requirement will remain at 0%. Considering the challenges posed by the COVID-19 pandemic, the FIN-FSA Board also decided that the maximum loan-to-collateral ratio will be adjusted and brought back to the statutory standard level of 90%. The Board also repealed its decision of March 28, 2018 on the reciprocation of the systemic risk buffer of 1.0% imposed by Bank of Estonia (Eesti Pank) on June 30, 2016. Finally, FIN-FSA is requesting all entities under the preparedness obligation to draw up an entity-specific preparedness plan and submit the plan to FIN-FSA by December 31, 2020.
Amendments to FIN-FSA Regulations and Guidelines on Reporting of Funding Plans
In the updated EBA guidelines (EBA/GL/2019/05) on reporting of funding plans, the definitions and breakdowns have been aligned with those used in FINREP reporting. The guidelines introduce a more detailed breakdown of market-based funding according to seniority, along with certain simplifications for small and non-complex institutions to enhance proportionality. According to the updated guidelines, the first reporting reference date is December 31, 2020, with the deadline for submitting the reports set for March 15, 2021. The FIN-FSA regulations and guidelines have been revised as follows:
- Paragraph (1) of section 2.2 referring to the EBA guidelines on the reporting of funding plans (EBA/GL/2019/05) has been amended, and a new paragraph (2) has been added to the section.
- A new section 2.3 on the decision of ECB has been added, and as a result the numbering of section 2.4 has changed.
- The reporting period under paragraph (4) of section 3.1 has been changed. It states that supervised entities shall submit the data collection concerning funding plans in accordance with the EBA guidelines (EBA/GL/2019/05) on an annual basis. Credit institutions shall submit the reports on their funding plans in accordance with these guidelines by March 15, with the reporting reference date being December 31 of the previous year.
The FIN-FSA regulations and guidelines 6/2014 apply to credit institutions which are identified as significant institutions in accordance with the criteria provided in the Regulation on the Single Supervisory Mechanism (SSM Regulation) and the SSM Framework Regulation, and which hence fall within the scope of direct supervision by ECB. This scope of application fulfills the recommendation of the ESRB that the data collection be applied to credit institutions covering at least 75% of the banking system’s total consolidated assets.
Preparedness Plans
FIN-FSA is requesting all entities under the preparedness obligation to draw up an entity-specific plan on how to ensure or intend to ensure the operability of critical services from an end-customer to an end-customer in circumstances where foreign service provision is completely unavailable. FIN-FSA announced that the Ministry of Finance is developing a regulation on the preparedness of the financial markets to be more unambiguous and better aligned with the requirements of the current operating environment. The entity-specific plan must describe, for example, how it is ensured that the payer is able to submit a payment order to its payment service provider and how the payment service provider processes the payment and transfers the payment to the payee's payment service provider and on to the payee's account. The plan must be based on a scenario where no inter-entity or entity-internal payment or securities system, function or data warehouse located abroad is available for months. The preparedness plan must be clear and detailed enough to enable the assessment of its feasibility and regulatory compliance. If the report includes actions to be taken in the future, their schedule and content must be presented in exact terms. The plans submitted to the FIN-FSA will be assessed by financial market authorities responsible for preparedness issues—that is, the Ministry of Finance and the Bank of Finland together with the FIN-FSA.
Related Links
- Press Release on Amendments to Regulations and Guidelines 6/2014
- Press Release on Macro-Prudential Decisions
- Press Release on Preparedness Plans
- Regulations and Guidelines 6/2014 (PDF)
- EBA Guidelines on Reporting of Funding Plans
- Decision on CCyB and Maximum LTC Ratio (PDF)
Keywords: Europe, Finland, Banking, Securities, COVID-19, Reporting, Funding Plans, FINREP, Proportionality, CCyB, Loan to Collateral Ratio, Macro-Prudential Instruments, Credit Risk, Systemic Risk Buffer, Preparedness Plan, Operational Risk, Eesti Pank, Basel, FIN-FSA
Featured Experts

María Cañamero
Skilled market researcher; growth strategist; successful go-to-market campaign developer

Nicolas Degruson
Works with financial institutions, regulatory experts, business analysts, product managers, and software engineers to drive regulatory solutions across the globe.

Patrycja Oleksza
Applies proficiency and knowledge to regulatory capital and reporting analysis and coordinates business and product strategies in the banking technology area
Previous Article
EBA Provides Clarity on Implementation of Certain COVID-19 PoliciesRelated Articles
BIS Report Notes Existing Gaps in Climate Risk Data at Central Banks
A Consultative Group on Risk Management (CGRM) at the Bank for International Settlements (BIS) published a report that examines incorporation of climate risks into the international reserve management framework.
EBA Publishes Multiple Regulatory Updates for Regulated Entities
The European Banking Authority (EBA) published the final guidelines on liquidity requirements exemption for investment firms, updated version of its 5.2 filing rules document for supervisory reporting, and Single Rulebook Question and Answer (Q&A) updates in July 2022.
APRA Consults on Prudential Standard for Operational Risk
The Australian Prudential Regulation Authority (APRA) is seeking comments, until October 21, 2022, on the introduction of CPS 230, which is the new cross-industry prudential standard on operational risk management.
EC Amends Rule on Securitizations; ESRB Updates Reciprocation Measures
The European Commission published a Delegated Regulation 2022/1301 on the information to be provided in accordance with the simple, transparent, and standardized (STS) notification requirements for on-balance-sheet synthetic securitizations.
APRA Announces Revisions to Capital Framework for Banks
The Australian Prudential Regulation Authority (APRA) is announced revisions to the capital framework for authorized deposit-taking institutions to implement the "unquestionably strong" capital ratios and the Basel III reforms.
EBA Examines Remuneration Data and Use of Large Exposure Exemptions
The European Banking Authority (EBA) published a report that examines the use of certain exemptions included in the large exposures regime under the Capital Requirements Regulation (CRR).
UK Authorities Publish Discussion Paper on Critical Third Parties
The Bank of England (BoE), the Prudential Regulation Authority (PRA), and the Financial Conduct Authority (FCA) published a joint discussion paper that sets out potential measures to oversee and strengthen the resilience of services provided by critical third parties to the financial sector in UK.
BoE Issues Update on Ongoing Data Transformation Program
The Bank of England (BoE) issued a communication to firms to provide an update on the progress of the joint data transformation program—which is being led by BoE, the Financial Conduct Authority (FCA), and the industry—for the financial sector in UK.
EBA Issues Draft Methodology and Templates for 2023 Stress Tests
The European Banking Authority (EBA) published the draft methodology, templates, and template guidance for the European Union-wide stress test in 2023.
EBA Issues SREP Guidelines and Standards for Investment Firms
The European Banking Authority (EBA) and the European Securities and Markets Authority (ESMA) jointly published the final guidelines on common procedures and methodologies for the supervisory review and evaluation process (SREP) for investment firms.