Review of Regulation on Improving Securities Settlement in the European Union and on Central Securities Depositories

Finance Finland is of the view, that the scope of settlement discipline should be clarified to avoid complicated interpretation.

Additional clarity on the scope of application of the following requirements under CSDR would provide further legal certainty, which

• legal entities
• securities
• type of transactions

fall under reporting obligations and the settlement discipline rules.

Rules relating to buy-ins: mandatory obligation should be removed, and it should be an optional right for the purchaser to execute a buy-in when the buyer is not a CCP. For CCP-cleared transactions, we retain that existing CCP mandatory buy-in rules should remain in place.