The Commission has given high priority to the Regulatory Fitness and Performance Programme (REFIT), which commits to a simple, clear and predictable regulatory framework. The Federation of Finnish Financial Services (FFI) comments on the programme and presents its views and suggestions for better financial sector legislation in general.
While regulation does carry an important role in the stabilisation of financial markets, development of the internal market, and implementation of consumer protection, it is also a fact that overlapping, conflicting and redundant regulation has been issued in some areas. The quality of legislation should be improved without reducing the obligations contained in the aforementioned important principles.
The next few years will also see a large volume of lower level regulation (level 2) finalised in the financial sector. This work involves national and European financial supervisors (EBA, ESMA and EIOPA), and will introduce a large amount of new and more detailed regulation into the financial sector. European supervisors are also currently preparing own-initiative guidelines and recommendations (level 3) which overlap with level 1 legislation in preparation.
It is already evident that the amount of regulation will multiply. This will bring challenges especially to small and medium-sized financial sector entities, which most financial companies in Finland are.
FFI’s opinion is that the multi-level regulatory framework that has been prepared must first be finalised and implemented, before any extensive legislative reforms are undertaken. It is absolutely essential to give priority to efficient implementation and uniform supervision.