Country _ Name
Finland
SectionTitle
Financial advisory and broking services including robo advisory and auto-trading
Body
FinTechs belonging to this category offer advisory and broking services for investments usually via an internet platform.

Robo advisory services usually offer an investment proposition following a series of questions concerning the personal financial background and the risk-bearing capacity of the user. Sometimes the respective platform also enables the user to directly execute the proposed investment. 

Auto-trading concerns all services which automatically trade on behalf of the customer according to his or her specifications.

Apart from that some FinTechs collect and offer merely or as an ancillary service market information or operate comparison portals to increase the transparency of the capital markets and to help the investor with his decision-making.

There are also FinTech-advertising-services which advertise various financial services or products.

Introduction

Attitude of the country towards modern financial advisory and broking services

Finland has a taken a neutral approach to modern financial advisory and broking services like robo-advisory and auto trading. While there are no specific national regulations targeting robo-advisers, operators providing such services must comply with the general requirements for investment services under MiFID II, which has been implemented nationally in the ISA. This includes obtaining proper authorisation from the FIN-FSA. Major traditional financial institutions like Nordea and OP Financial Group have launched robo-advisory solutions, while some of the independent providers have been integrated into larger banking groups. The regulatory framework supports the use of technology in financial services without bias against digital platforms.


Legal affairs

Obligations and requirements to provide financial advisory and broking services, or ancillary services described above

Business activities involving the provision of investment services are subject to the ISA (747/2012). FinTechs providing such services need to meet the same requirements as the traditional asset and portfolio management service providers. Under the ISA, the provision of investment services is subject to authorisation granted for specifically defined investment services (such as asset management) and ancillary services (such as custody). The FIN-FSA grants authorisations on application to investment firms domiciled in Finland where it can be ascertained, based on accounts obtained, that the applicant meets the requirements for authorisation. The prerequisites are related widely to the organisation of the firm’s activities, code of conduct with the customer as well as financial position.

In Finland, investment firms offering financial advisory and broking services, including algorithmic trading and direct electronic access, must comply with specific regulations under the ISA.

Firms engaged in algorithmic trading must establish effective systems and risk controls to ensure the resilience and capacity of their trading systems and comply with EU market abuse regulations and trading venue rules (ISA, Chapter 7a, Section 1). The entities engaged in algorithmic trading must notify the FIN-FSA and trading venue authorities of their algorithmic trading activities and maintain records of orders, including cancelled and executed orders.


Additional comments regarding the legal situation for financial advisory and broking services, or adjacent services or what FinTech’s must be aware of in this business area

Entities providing Direct Electronic Access to trading venues are required to have systems in place to assess client suitability, monitor trading, and prevent activities that could lead to market abuse or disorderly trading (ISA Chapter 7a, Section 3). These firms must ensure that clients adhere to the ISA, the Act on Trading in Financial Instruments, and the rules of the trading venue.


Economic conditions

Market size for financial advisory and broking services as well as adjacent services and biggest companies in this business area

N/A

Additional comments regarding the economic situation for financial advisory and broking services as well as adjacent services or what FinTech’s must be aware of in this business area

N/A



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