FINFSA Mortgage Banking Risk


On Mar. 26, FINFSA consulted on risk management regs, guidelines.


  • FINFSA called for comments on compilation of draft regulations and guidelines X/2024 on procedure for risk management in mortgage banking.
  • Background
  • Draft regulations issued on basis of the Act on mortgage credit banks and covered bonds (Act 151/2022) which implemented the covered bonds directive 2019/2162 into national law, and entered into force on Aug. 7, 2022.
  • Proposed regulations and instructions would repeal regulations, instructions 6/2012.
  • Purpose of regulations and guidelines is to guide procedures of mortgage credit banks and licensed credit institutions where guidance is not available from the legislation.
  • Effectiveness
  • The response period ends on Apr. 23, 2024; feedback planned to be published in May.
  • Oct. 2024 Finalized Regulations and Guidelines
  • On Oct. 21, 2024, FINFSA issued finalized mortgage bank regulations and guidance.
  • Among other things, updated regulations and guidelines includes FINFSA's recommendation on annual confirmation by supervised entity's Board.
  • Specifically, Board of Directors of the business plan should be presented in connection with license application under s. 8, UKPL, and elements of business plan included.
  • FINFSA issues regulations on calculation and valuation methods of overcollateralization as per s. 24, UKLPL and on monitoring of overcollateralization rates.
  • Also, a regular assessment of the impact of alternative scenarios on the amount of overcollateralization and considering effects when determining risk appetite/limits.
  • FINFSA also issues a recommendation on the information to be entered in the bond register as per s. 27, UKLPL and on storage of records of bond register entries.
  • As per new regulations FINFSA will issue order requiring documentation of the calculation method for a liquidity coverage requirement as per s. 31 of the UKLPL.
  • Also, that the method has been approved by supervised entity's Board of Directors.
  • Includes recommendation on a regular assessment of the impact of alternative scenarios on the cash flows and maximum net outflow quantities of contracts.
  • Also, considering these effects when determining risk appetite and risk limits.
  • FINFSA issues a recommendation on content of the application for postponement of the maturity of a covered bond referred to in s. 32, UKLPL and application procedures.
  • An authorized credit institution that is not a mortgage credit bank as per Collection of Regulations and Guidelines organizes its risk management on mortgage banking.
  • Specifically comprising into a single entity, so that it has the capacity to separate the function into an independent entity in the event of resolution.
  • Regulations and Guidelines 2/2024 repeal Regulations and Guidelines 6/2012.
  • FINFSA states that Regulations and Guidelines 2/2024 are effective Jan. 1, 2025.

Regulators FINFSA
Entity Types Bank; MG Orig
Reference Reg 2/2024, Gd FIVA/2024/244, PR 10/21/2024; PR, CP, FIVA/2024/244, 3/26/2024; CBD Dir 2019/2162; UKPL (FIN); UKLPL (FIN); VKLPL (FIN)
Functions Actuarial and Valuation; C-Suite; Financial; Legal; Operations; Record Retention; Resolution; Risk; Treasury
Countries Finland
Category
State
Products Banking; Loan; Mortgage
Regions EMEA
Rule Type Final
Rule Date 3/26/2024
Effective Date 1/1/2025
Rule Id 206335
Linked to N/A
Reg. Last Update 10/21/2024
Report Section EU

Last substantive update on 10/24/2024